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Liquid Gas Europe

Liquid Gas Europe represents the European liquid gas industry at EU level and contributes to policy development in energy, transport, environment and taxation.

Lobbying Activity

Meeting with Jens Geier (Member of the European Parliament)

21 Jan 2026 · Exchange on implementation of the gas and hydrogen market package

Meeting with Nicolás González Casares (Member of the European Parliament)

21 Jan 2026 · LPG

Meeting with Yannis Maniatis (Member of the European Parliament) and European Federation of Pharmaceutical Industries and Associations

20 Jan 2026 · Introductory Meeting

Meeting with Pietro Fiocchi (Member of the European Parliament) and Vestas Wind Systems A/S

20 Jan 2026 · tematiche ambientali

Meeting with Maria Grapini (Member of the European Parliament)

19 Jan 2026 · renewable liquid gases

Liquid Gas Europe Urges Recognition for Renewable Heating Fuels

9 Oct 2025
Topic — The EU is developing a strategy to decarbonize heating and cooling sectors across Europe.
Message — The industry calls for renewable liquid gases to have equal status with electrification. They advocate for a neutral policy that rewards emissions performance over specific technologies. Finally, they request financial aid for rural households switching to these renewable fuels.123
Why — This would preserve their market share while avoiding expensive infrastructure and equipment upgrades.45
Impact — Solid biomass producers face competition as their fuels are described as highly polluting.6
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Meeting with Peter Liese (Member of the European Parliament) and Negative Emissions Platform and FGS Global (Europe) GmbH

18 Sept 2025 · Austausch

Liquid Gas Europe demands technology neutrality for 2040 target

16 Sept 2025
Topic — Amending the European Climate Law to include a 2040 greenhouse gas target.
Message — Liquid Gas Europe calls for a technology-neutral framework that treats renewable liquid gases on an equal footing with other solutions. They request a pragmatic certification system and consistent treatment across all EU climate and energy legislation.12
Why — This would unlock private capital and prevent their products from being disadvantaged by higher taxes.34
Impact — Rural citizens face higher energy costs if the framework excludes cost-effective off-grid heating solutions.5
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Liquid Gas Europe Urges Technology-Neutral Support for Rural Heating

10 Sept 2025
Topic — A consultation on protecting and empowering consumers during the just energy transition.
Message — Liquid Gas Europe requests a technology-neutral approach that includes renewable liquid gases like bioLPG. They advocate for directing Social Climate Fund resources specifically to vulnerable rural households.12
Why — This approach would protect their market share by keeping gas-based heating infrastructure viable.34
Impact — Heat pump manufacturers may lose potential customers if gas boiler bans are avoided.56
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Response to Revision of the Standardisation Regulation

21 Jul 2025

Liquid Gas Europe (LGE), the representative body for the European liquid gas sectorincluding both conventional and renewable gases such as LPG, bioLPG, and renewable DMEwelcomes the European Commission's revision of the Standardisation Regulation. The association emphasizes the importance of standards in ensuring the safe production, transport, storage, and use of liquid gases and highlights its active participation in European and international standard-setting bodies (CEN and ISO) LGE expresses general support for the objectives of the revision but raises important concerns regarding the proposal to accelerate and simplify standard development. Many industry experts contribute to this process on a voluntary basis, and compressing timelines could compromise quality and safety. LGE warns that insufficient review time might lead to errors or omissions in standards, especially in high-risk sectors like liquid gas. The association recommends maintaining the existing level of rigour while using existing streamlined procedureslike bypassing a formal vote when appropriatewhere possible. One specific area LGE identifies for improvement is the harmonisation process. It criticizes the current system where Harmonised Standards (HAS) consultants are contracted externally, leading to delays, inconsistent assessments, and limited feedback. Previously, HAS consultants were more engaged and helped standard drafters meet harmonisation requirements. Now, their assessments often lack practical guidance. LGE suggests that bringing HAS consultants under in-house control and involving the CEN-CENELEC Management Centre (CCMC) earlier in the process could resolve these inefficiencies and improve harmonisation outcomes. In terms of supporting the EU's climate goals, LGE calls for a coordinated and well-resourced revision of standards relevant to renewable liquid gases. This would involve multiple technical committees and is critical to enabling the industry's transition away from fossil-based products. Without additional resources and active coordination, the necessary changes may not be achieved within the targeted timeframe. LGE also stresses the need for broader and more transparent access to draft and final standards. These documents are vital to ensure safety and compliance not only for industry but also for policymakers, regulators, and small and medium-sized enterprises (SMEs). LGE supports measures to improve accessibility, particularly for public authorities and SMEs, in line with legal obligations and recent case law. At the international level, LGE underscores the importance of maintaining the EUs influence within ISO and other global standardisation efforts. The organisation highlights the key contributions of European stakeholders to global standards and calls for a revised Regulation that ensures continued alignment between EU and international frameworks. Strengthening the EUs global leadership is seen as essential to preserving strategic competitiveness and credibility. In conclusion, LGE supports the Commissions intention to modernise the standardisation system and commits to ongoing engagement. The association recommends caution when altering development timelines, advocates for targeted improvements in harmonisation practices, and supports better coordination, access, and international alignment. It seeks a regulatory environment that balances safety, efficiency, and inclusiveness, while reinforcing the EUs role as a global standard-setter.
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Meeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

3 Jul 2025 · Exchange of views on alternative fuel

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and SHV Energy NV and

1 Jul 2025 · Decarbonisation of agriculture

Meeting with Alina Nedea (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

1 Jul 2025 · BioLPG as a decarbonization solution for rural areas

Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra)

1 Jul 2025 · Liquid Gas industry, decarbonization goals

Response to European Affordable Housing Plan

4 Jun 2025

Liquid Gas Europe Consultation Response: European Affordable Housing Plan Heating affordabilityand recognition of the distinct needs of both urban and rural communitiesmust lie at the heart of the European housing strategy. For Liquid Gas Europe, affordable and sustainable housing is not just a social goal; it is a cornerstone of social inclusion, territorial cohesion, and a just energy transition. As advocates for cleaner, secure, and accessible energy, we emphasise that affordable heating and consumer choice are essential to this vision. This is especially true in rural and remote areas, which make up most of the land in EU Member States and are home to nearly 137 million peoplemany facing higher energy costs, limited infrastructure, and fewer viable options for decarbonising heat. 1. Energy Poverty and Heating Costs Energy poverty disproportionately affects vulnerable households, especially in older or inefficient buildings where heating costs are high. Reducing these costs is critical to tackling housing overburden and enabling affordable living. While electrification is part of the solution, it is not always affordable, practical, or feasible across the EUs diverse building stock and climates. A technology-neutral approach is needed to enable solutions adapted to local conditions and consumer needs. 2. Affordability through Energy Choice A one-size-fits-all approach to building decarbonisation risks excluding low-income and rural households. Energy choice should reflect consumer preferences, regional realities, and available infrastructure. A diverse mix of clean heating options will accelerate progress and protect affordability. Moreover, state aid and tax frameworks must treat renewable fuels on equal footing with other low-carbon technologies, ensuring investment flows where it delivers the greatest social and economic benefit. 3. The Role of Renewable Fuels in Decarbonising Heat Liquid gasessuch as LPG and renewable liquid gasesoffer a cost-effective route to decarbonise heating in existing buildings, particularly where electrification is costly or impractical. RLGs work with existing infrastructure and appliances, enabling gradual decarbonisation without disruptive renovations or high upfront costscrucial for affordable and social housing. Their off-grid capability and flexible storage make them especially valuable in rural and remote EU regions. Hybrid systems combining renewable gases with electric heating can reduce pressure on electricity grids during winter peaks while delivering more stable, affordable heat. To support inclusive and resilient decarbonisation, EU heating and renovation policies must remain open to a mix of technologiesallowing renewable gases like bioLPG to complement electrification and shield vulnerable consumers from price volatility. We urge the Commission to: Explicitly recognise renewable gaseous fuels as part of the solution for decarbonising heat in affordable housing, alongside heat pumps, district heating, and other technologies. Promote inclusion of renewable liquid gases in national renovation strategies, especially for off-grid areas and regions where full electrification would impose economic or technical burdens. Ensure EU funding instrumentssuch as the EU Cohesion Policy, the Social Climate Fund, and other relevant mechanismssupport renewable gas technologies (e.g. bioLPG, renewable DME) in both new housing and energy renovation, particularly in off-grid and hard-to-electrify areas. In conclusion, affordable housing is not only about the initial cost of a dwellingit is about the long-term cost of living, including energy, and the challenges faced by rural, remote and off-grid communities should be considered when considering a European housing plan and ensuring that a range of solutions are considered to ensure that these communities are afforded access to low-carbon energy solutions which are affordable and practical.
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Liquid Gas Europe opposes pollutant costs in building energy rules

7 May 2025
Topic — The Commission is revising the methodology for calculating minimum energy performance in buildings.
Message — Liquid Gas Europe opposes pollutant costs, proposing a minimum emission threshold for exemptions. They want the framework to recognize BioLPG and update emissions databases.123
Why — This avoids financial penalties that would make liquid gases less competitive than electricity.45
Impact — Electric appliance manufacturers lose the competitive advantage of zero tailpipe emission ratings.67
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Liquid Gas Europe Urges Inclusion of Renewable Liquid Gases

26 Mar 2025
Topic — Amendments to EU Taxonomy reporting to simplify requirements and reduce business costs.
Message — The association wants renewable liquid gases included as eligible economic activities. They also seek transitional status for LPG to aid off-grid decarbonization.12
Why — These changes would facilitate investment and reduce administrative burdens for gas distributors.34
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Meeting with Kateřina Konečná (Member of the European Parliament)

23 Oct 2024 · Introduction of political priorities

Meeting with Dariusz Joński (Member of the European Parliament)

23 Oct 2024 · European and Polish LPG sector

Meeting with Tomáš Zdechovský (Member of the European Parliament)

23 Oct 2024 · Talk with a deputy of a nonprofit association that represents the voice of the liquid gas industry in Brussels. Included topics were renewable sources of energy, CO2 reduction policy or another alternatives to internal combustion engines

Meeting with Jeannette Baljeu (Member of the European Parliament)

23 Oct 2024 · Fuel legislation

Meeting with Lukas Mandl (Member of the European Parliament)

23 Oct 2024 · Energy

Meeting with Waldemar Buda (Member of the European Parliament)

22 Oct 2024 · Rola gazów płynnych w transformacji energetycznej Europy

Meeting with Yvan Verougstraete (Member of the European Parliament)

22 Oct 2024 · Energy supply

Meeting with Krzysztof Hetman (Member of the European Parliament)

22 Oct 2024 · Situation on the european liqued gas market

Meeting with Yvan Verougstraete (Member of the European Parliament, Committee chair)

22 Oct 2024 · Prise d informations

Meeting with Giorgio Gori (Member of the European Parliament) and IVECO GROUP N.V.

22 Oct 2024 · Presentation of priorities

Meeting with Nina Carberry (Member of the European Parliament)

22 Oct 2024 · EU Energy Policy

Meeting with Ondřej Dostál (Member of the European Parliament) and E-MOBILITY EUROPE

22 Oct 2024 · Introduction

Meeting with Pascal Arimont (Member of the European Parliament)

22 Oct 2024 · EU’s energy and environmental goals

Meeting with Maria Walsh (Member of the European Parliament)

22 Oct 2024 · Liquid Gas Ireland

Meeting with Angelika Winzig (Member of the European Parliament)

22 Oct 2024 · Meeting with representatives of Liquid Gas Europe

Meeting with Andreas Glück (Member of the European Parliament) and BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V.

31 Jul 2024 · Climate and Energy Policy

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

26 Oct 2023 · To discuss with you several developments within the “Fit for 55” package which will impact our sector.

Liquid Gas Europe warns of unfeasible fuel tracking costs

23 Aug 2023
Topic — This consultation updates rules for monitoring and reporting greenhouse gas emissions under the revised EU ETS.
Message — The organization requests a review of Article 75l to avoid unreasonable costs for determining fuel use beforehand. They also recommend that the regulation explicitly allow the mass balance method for determining bio-based content.12
Why — This would lower administrative burdens and prevent unfeasible monitoring requirements for LPG distributors.34
Impact — End users will face higher energy prices if industry tracking costs are passed on.5
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Meeting with Frances Fitzgerald (Member of the European Parliament)

29 Jun 2023 · Ecodesign Implementing Regulation

Meeting with Andreas Glück (Member of the European Parliament) and European Biodiesel Board and Bioéthanol France

28 Jun 2023 · HDV

Meeting with Chris Macmanus (Member of the European Parliament)

28 Jun 2023 · Ecodesign Directive (meeting taken by staff)

Liquid Gas Europe Urges Euro 7 Support for Carbon-Neutral Fuels

8 Feb 2023
Topic — The European Commission is proposing stricter pollutant emission standards for all combustion-engine vehicles.
Message — Liquid Gas Europe wants policymakers to consider LPG a clean fuel under Euro 7 rules. They seek to future-proof internal combustion engines using carbon-neutral fuels after 2035. Finally, they request appropriate leeway for manufacturers before the new regulations apply.12
Why — This would preserve existing infrastructure and maintain a market for internal combustion technology.3
Impact — Electric vehicle producers lose their status as the only providers of zero-emission mobility.4
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Liquid Gas Europe Urges Reclassification of Biofuel Feedstocks

23 Dec 2022
Topic — The Commission is updating the list of sustainable biofuel feedstocks for renewable energy.
Message — The group suggests including all Part B feedstocks in Part A instead. They argue the Part B cap limits investments for renewable liquid gases.12
Why — Avoiding the Part B cap would prevent investment curtailment for renewable gas production.3
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Meeting with Iskra Mihaylova (Member of the European Parliament)

11 Nov 2022 · discussion on Energy Performance of Buildings Directive (EPBD)

Meeting with Jens Gieseke (Member of the European Parliament)

9 Nov 2022 · Austausch zur Energiepolitik

Meeting with Cristian-Silviu Buşoi (Member of the European Parliament)

13 Sept 2022 · EPBD Directive

Response to Energy labelling requirements for local space heaters (review)

15 Aug 2022

Liquid Gas Europe is a European association composed of national LPG associations, main LPG suppliers, distributors and equipment manufacturers of LPG and renewable LPG including bioLPG, renewable DME (rDME) and other drop-in and complementary gases. We advocate for a safe, supportive legislative and regulatory environment for the liquid gas industry to thrive and enable its transition to being 100% renewable by 2050. A thriving and innovative European liquid gas industry will ensure a just energy transition for our industrial and domestic customers, both on the road and off-the-grid. On the Biomass Label Factor, we believe that the primary, intended purpose of the energy label is to display the energy efficiency class of the product to enable a consumer to make an informed choice based upon energy efficiency and not on the fuel type. Including a biomass label factor creates a false picture of energy efficiency in favour of biomass at the expense of alternative fuels. We instead suggest a "Renewable Energy Factor Label", which recognizes the role that all renewable fuels continue to play in heating homes. We strongly believe that the scope should not be expanded to include electric space heaters and air-to-air heat pumps. It is more useful to see the energy rating of similar devices, rather than the relative performance of a very wide range, in terms of technology and price. Additional labelling or information on the GHG emissions and air pollutants should be required, and the F2 and F3 correction factors should be reconsidered.
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Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)

21 Jun 2022 · Rural Futures and the EPBD (Webinar)

Liquid Gas Europe urges fair greenhouse gas calculation rules

17 Jun 2022
Topic — Establishing a methodology to assess greenhouse gas savings for non-biological renewable fuels.
Message — The association requests including hydrogen compression emissions and using economic value for allocation. They also call for LPG to be added to the standard values table.123
Why — These changes would ensure a level playing field between hydrogen and liquid gases.4
Impact — Hydrogen producers would face higher carbon ratings if compression and distribution emissions are included.5
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Meeting with Andreas Schieder (Member of the European Parliament, Rapporteur) and smartEn Smart Energy Europe

24 May 2022 · Exchange of Views EPBD

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

40 million homes in the EU are not connected to the gas grid. In these areas the current fuel mix is still dominated by the usage of heating oil and coal. The revision of the Energy Performance of Buildings Directive (EPBD) opens an opportunity for policymakers to set up a pathway to cleaner and more efficient buildings in Europe. The rural and off-grid building stock should be looked at particularly closely due to their reliance on heating oil and coal, and given that nearly 25% of people in rural areas are at risk of poverty or social exclusion . Liquid gases offer environmental benefits such as lower GHG emissions and less air pollution in comparison to heating oil and coal. At the same time, they are a cost-effective option for consumers facing financial difficulties, as they do not require expensive storage facilities and can be transported easily at ambient temperatures. In addition, renewable liquid gases (e.g. rLPG/bioLPG) act as a drop-in replacement for LPG, removing the need for new and expensive infrastructure. We are strongly convinced that consumers’ choices and needs should be at the core of the new EPBD. Liquid Gas Europe suggest to: 1. Introduce a mixed technology approach to EPBD: use the potential of electricity as well as liquid gases to decarbonise rural buildings. The new EPBD should not establish a priori which technology is the best to drive the decarbonisation of the EU buildings stock. A one-size-fits-all approach based on electrification fails to consider the diversity of the EU’s building stock and the different needs of rural and off-gas-grid buildings. Relying solely on electricity as a heating source for households or businesses in rural areas would require new infrastructure and new backup options to manage a higher energy demand. At the same time, the transition of rural heating from heating oil to liquid gases and renewable liquid gases offers a great decarbonisation potential. A mixed technology approach is the best solution to tackle the decarbonisation of buildings within the EU. 2. Ensure renewable gases such as rLPG, bioLPG and rDME are recognised for their contribution to the decarbonisation of buildings. The current description of a “zero-emission building”, whose primary energy consumption is “fully covered by energy from renewable sources generated on-site” is concerning. Together with language on “zero direct emissions building” this would seem to prevent any building from using renewable fuels to generate renewable heat and/or renewable electricity on-site. This generated on-site requirement constitutes an unjustified market barrier. It would narrow down consumers’ choices to solar power, wind turbines, and heat pumps while excluding the use of renewable gases such as bioLPG and rDME. This would be problematic for many buildings, including hard-to-electrify, rural buildings with limited space for solar PV and wind generation. BioLPG, rDME and other renewable gases, even if not generated on-site, are of non-fossil origin and provide immediate emissions reductions compared to other heating fuels. They have an important contribution to make in decarbonising the European building stock in new buildings and in reducing emissions from existing buildings.
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Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur) and European Alliance to Save Energy and

31 Mar 2022 · The Energy Performance of Buildings Directive - Stakeholder Event

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and European Biodiesel Board and NGVA Europe

9 Feb 2022 · Austausch zur EU-Verkehrspolitik

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Renewable Liquid Gas, also known as bio-propane (RED II, Annex III), Renewable LPG,or bioLPG, is a renewable liquified gaseous fuel that is already available today on the European market in growing quantities. Renewable LPG is chemically and physically identical to conventional LPG, allowing industry and consumers to seamlessly transition to a renewable solution. Renewable DME (rDME) also offers huge opportunities for near term decarbonisation, not only in the transport sector but also in industrial and domestic heating and cooking applications. To accelerate the take-up of bioLPG and rDME in the EU and make a decisive contribution to the EU’s ambition of reducing net greenhouse gas emissions by at least 55% by 2030 – and ultimately becoming climate neutral by 2050 – Liquid Gas Europe urges the European Commission to consider the following recommendations: 1. Ensure a regulatory framework which supports the production of renewable gaseous fuels and incentives their uptake to help achieve the increased RES target Liquid Gas Europe supports the European Union’s Green Deal objectives and has showcased that 100% of the product that LPG companies will distribute in 2050 can come from renewable sources. To achieve this, however, a right regulatory framework needs to be put in place which a) gives confidence to industrial actors to invest in the emergence of innovative solutions for the production of renewable liquid gas, b) supports the R&D activities and further production of renewable gaseous fuels, and c) incentivises their use. Should this be put in place, Liquid Gas Europe supports the renewable energy targets put forward by the Commission in their proposal. 2. Recognise all relevant production pathways of bioLPG and rDME It is key that rLPG and rDME are included in the comprehensive terminology for renewable fuels and that the annexes are amended to reflect the technological state of play with regard to production pathways. A list of production pathways is included in the Annexes of this submission. 3. Define renewable LPG alongside other renewable liquid and gaseous fuels or include all variants in Annex III of the Directive Please find in the Annexes of this submission a proposal for the inclusion of bio-propane, bio-butane, propane from renewable sources and butane from renewable sources in Annex III of the Renewable Energy Directive. 4. Create a stimulating regulatory framework for RFNBOs and recycled carbon fuels The definition of RFNBOs should be amended, ensuring that they can be counted as renewable energy regardless of the sector in which they are consumed, which will encourage the development and the production of rDME. Liquid Gas Europe calls on the Commission to shortly specify the methodology for assessing greenhouse gas emissions savings from RFNBOs and RCFs. We also call to include RCFs in the calculation of the greenhouse gas reduction target by default. 5. Introduce requirements for air pollution in sustainability criteria The revised sustainability criteria should contribute to coherence and synergies with the air quality objectives of the zero-pollution action plan, while avoiding trade-offs which is currently the case when it comes to the use of wood biomass in residential heating. 6. Ensure sustainability certificates and Guarantees of Origin are compatible and complementary Liquid Gas Europe considers that the revision of the directive should facilitate cross-border trade of renewable LPG and its recognition under different policy instruments. For gaseous fuels, sustainability certificates could be issued using the mass balancing system defined by RED II until the product enters downstream distribution value chain. Once the renewable gas enters the distribution infrastructure, GOs should become the main instrument to carry information.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

The European LPG industry is fully committed to reaching carbon neutrality in road transport by 2050 at the latest. LPG is the number one alternative fuel in Europe and with its clean burning properties, it has provided more environmental benefits to date than any other alternative fuel. Moreover, LPG can be readily replaced with its defossilised version BioLPG and be increasingly blended with rDME. Therefore, LPG together with bioLPG and rDME are resource-efficient gaseous fuels that are perfectly placed to immediately help to reach this goal, especially as an affordable and practical solution in road transport. Regarding the proposal for Alternative Fuels Infrastructure Regulation, Liquid Gas Europe calls on EU policy makers to take the following legislative recommendations into account: 1. Keep the scope of the definition of alternative fuels, including LPG, to respect a technologically neutral approach and ensure all fuels and technologies can play a role in decarbonising the EU’s transport sector. Liquid Gas Europe welcomes the revision of the Alternative Fuels Infrastructure Directive. We welcome that LPG continues to be included in the scope of the definition of alternative fuels. We welcome that the Regulation acknowledges the importance of such a mature fuel by keeping LPG in the definition of alternative fuels. Such definition sends the right signal to enable continuous support to a fuel with a track record of success that provides environmental benefits through millions of vehicles already on the road. Forward-looking, this also stimulates investments in bioLPG and rDME – fuels that will increasingly decarbonise LPG towards carbon neutrality In 2050. 2. Clarify the definition of alternative fuels to ensure bioLPG and rDME are recognised as renewable fuels which can decarbonise the transport sector. Given the significance of the transport sector in the drive towards climate neutrality, a progressive uptake of renewable fuels is essential to achieve these objectives. For this reason, it is important to consider LPG in the context of bioLPG and a blending fuel with similar properties rDME. Replacing or blending LPG with these fuels can immediately reduce life cycle GHG emissions. The proposed definition of alternative fuels should provide more clarity on which type of fuels are considered renewable, in line with the Renewable Energy Directive. 3. Consider the social aspects of the energy transition and ensure “no one is left behind” by retaining access to affordable mobility and the capability of bioLPG and rDME to progressively decarbonise the legacy vehicle fleet. We welcome that the proposal continues to support a wide range of alternative fuels available to consumers. With over 8 million vehicles running on LPG in the EU, either through new car purchases or retrofits of existing cars, LPG is clearly consumer-accepted when compared to other fuels.Because LPG can be easily replaced with BioLPG and blended with rDME, the ability of such renewable fuels to ensure “no-one is left behind” is invaluable; reducing pollutant emissions while enabling access to affordable mobility and the capability to progressively decarbonise the legacy vehicle fleet are key advantages of LPG and cannot be overlooked. LPG, therefore, fills a market segment that other more expensive technologies like electric vehicles are unable to penetrate in the foreseeable future. 4. Ensure consistency across legislation to promote and develop alternative fuels in Europe. To ensure rapid uptake of renewable fuels in the EU market across all sectors, including bioLPG and rDME, it is important to send the right signal to the industry and the citizens; the signal that production and use of renewable fuels will be supported in the long term by coherent legislation and policies. This can only be achieved if measures and incentives are consistent across legislative files.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The current ETD has incentivised the uptake of LPG and contributed to meeting the EU climate objectives. Liquid Gas Europe recognises however that the rules are outdated and therefore welcomes the proposal on the revision of the Directive. To enable LPG and renewable LPG to fulfil their potential to contribute the European Green Deal, we call on policy-makers to take the following feedback into account: 1) Create appropriate price signals enabling LPG to play its role in the energy transition: distinguish between low-carbon and high-carbon fossil fuels We welcome the proposed new structure of the Directive, basing the minimum rates on the energy content of fuels and their environmental performance. In particular, we welcome the recognition of LPG as a fuel with clear environmental benefits over conventional fossil fuels and an important contribution to make to the green transition. We are however concerned about the proposed minimum levels of taxation for LPG used as a heating and a transport fuel. Under the current proposal, the minimum level of taxation on LPG used in transport and in heating would drastically increase. A drop-in fuel, bioLPG and renewable LPG can be blended with LPG and used in existing appliances. Its further uptake is hence also tied to the competitive advantage of its fossil counter-part over conventional fuels. We also regret that after the transition period, the Directive will not distinguish between LPG and high-carbon fossil fuels. LPG will still emit considerably less greenhouse gas emissions as well as air pollutants compared to conventional fossil fuels. 2) Clarify to what extent Member States need to replicate the ranking of minimum levels of taxation The proposal is ambiguous about the extent to which Member States can adapt the structure of minimum tax levels. Should they only respect the ranking structure or should they also keep the relations between the different ranks (fuels of rank 2 should always be 2/3 of fuels of rank 1; fuels of rank 3 should always be 1/2 of fuels of rank 1)? We are not in favour of replicating the relations between the different ranks. 3) Support alternative fuels with a track record of success It is important that Member States retain the flexibility to tailor their sustainable transport strategies to their national context. For Member States with a strong track record of alternative fuels uptake and investments in infrastructure developments that want to continue to incentivise the uptake of certain fuels to meet their specific market needs, the revised ETD should allow flexibility to maintain this standard practice in the spirit of policy continuity and fuel price stability for consumers. 4) Give member states the necessary flexibility to tailor energy taxation to needs of rural areas Due to their specific characteristics, rural areas are hard-to-decarbonise. In order to avoid exacerbating energy poverty, and secure the competitiveness of rural businesses, Member States should have the possibility to provide specific derogations to energy used for heating purposes in both residential and business applications. Liquid Gas Europe welcomes the possibility for member states apply a reduction to heating fuel used by households. We believe that Member States should also have the possibility to apply a reduced rate for rural businesses. 5) Ensure consistency with the Renewable Energy Directive (RED) The ETD proposal is not fully consistent with the RED. The proposed biogas categories are neither clear, nor consistent with REDII. This would bring legal confusion. The categories “sustainable food and feed crop biogas” and “sustainable biogas”, should be merged into one. The distinction between the two, as proposed, is not grounded in the RED II. Food and feed crop based gases have to comply with stringent sustainability and greenhouse gas savings defined in REDII to be counted towards the renewable energy targets.
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Response to Revision of the CO2 emission standards for cars and vans

4 Nov 2021

Please find attached Liquid Gas Europe's joint response with other Members of the Renewable & Low Carbon Liquid Fuels Platform on the open public consultation on the revision of CO2 emission performance standards for cars and vans [Regulation (EU) 2019/631].
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Response to New EU urban mobility framework

25 May 2021

Liquid Gas Europe, the European LPG Association, is composed of national LPG associations, suppliers, distributors and equipment manufacturers. We are committed to engage with European policy makers and stakeholders on the clean, available and innovative properties of LPG and BioLPG as energy solutions, in particular for the heating and cooling, and mobility sectors. LPG (a mix of propane and butane) is a by-product of natural gas extraction and oil refining, and thus energy efficient by nature. Autogas (LPG as a transport fuel) is an immediately available alternative, offering significant environmental and economic advantages. It emits up to 20% less CO2 than petrol, and up to 98% less NOx than diesel. It is the number one alternative fuel in Europe, accounting for 77% of the existing alternatively-fuelled vehicles, or approximately 15 million vehicles in circulation. It’s also affordable, with an average savings of 50% compared to conventional fuels. It also consist of an established refuelling network of almost 48K stations in Europe. In the context of the European Green Deal and the Sustainable and Smart Mobility Strategy, Liquid Gas Europe acknowledges the need to mitigate the negative external environmental and health costs derived from the predominant market share of conventional fuel used by the transport sector. Drawing from the European Commission’s analysis, air quality greatly impacts inhabitants of European cities, rural and peri-urban areas, data showing 80% of urban European population being exposed to PM levels exceeding World Health Organisation guidelines. Having European cities’ concentrations of NO2 and PM10 consistently above the EU limit values, and transport being the main contributor to NOx emissions, using Autogas in the transport sector entails an immediate opportunity to contribute to the quality of air in European cities. Autogas is available for all vehicle segments, from private cars to delivery vans. It is an immediately available alternative to diesel and petrol, with benefits for consumers, the environment and the economy alike. It is a low-hanging fruit for tackling Europe’s climate change and air pollution challenges. In order to improve air quality by reducing harmful transport-related emissions in cities, rural and peri-urban areas, Autogas has the potential to act as a complementary solution to emerging technologies, such as electric vehicles. It can be incentivised in the short-term, both for private usage and public transport to lower emissions today. Furthermore, vehicles fuelled by Autogas can become fully renewable by switching to or blending with BioLPG, which has a carbon footprint up to 80% lower than conventional LPG, and is chemically identical, making it easy to switch to this renewable alternative. BioLPG is already commercially available in small but growing quantities. Future additions to the Autogas portfolio, like synthetic LPG and rDME as also emerging, that have the potential to make Autogas carbon negative. An example of how urban mobility can improve air quality for citizens across Europe is furthering the establishment of Low Emission Zones (LEZs), which prevent vehicles with higher emission levels accessing specific areas, or to charge them to access such areas. Given that Autogas vehicles generate almost no particulates or black carbon, these vehicles may have favourable access to LEZs, hence directly contributing to the improvement of urban mobility air quality. For this reason, Liquid Gas Europe encourages the European Institutions to further support the establishment of LEZs within the new EU Urban Mobility Framework. We support full access and/or an exemption from LEZ charges for all cars powered by LPG, including retrofitted vehicles, in light of the numerous benefits it brings for health and the environment.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Liquid Gas Europe would like to contribute by providing feedback to the roadmap on the revision of the EPBD. Please find our comments and suggestions attached.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Please find Liquid Gas Europe's feedback on the Impact Assessment attached.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG and bioLPG suppliers, distributors and equipment manufacturers. With the support of its working groups composed of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe. Liquid Gas Europe wishes to share the LPG industry’s input on the roadmap for the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil – building a Healthier Planet for Healthier People”. We find this initiative of critical importance as it aims to improve European citizens’ health and quality of life, notably by reducing air pollution in rural areas as well as cities throughout Europe. Liquid Gas Europe has been actively involved in the fitness check of the two Ambient Air Quality Directives, contributing to the consultations and participating in the stakeholder meetings. In our feedback, Liquid Gas Europe would like to focus on the unique characteristics of the heating energy landscape beyond the gas grid and its impact on air quality. There are around 40 million homes located in rural areas in Europe without access to the gas grid . There is also untapped potential to accelerate pollutant emissions reduction efforts from 250 million passenger cars on European roads. The Zero Pollution Ambition should aim at facilitating the transition to solutions that can reduce both carbon and air pollutant emissions in a cost-efficient way. To this end, the LPG and bioLPG industry invites the European Commission to consider focusing on the following aspects to be included in the EU Action Plan: 1. Alignment of EU air quality standards with WHO guidelines 2. Phasing out policy support for energy solutions having both high GHG and air pollutant footprints in the upcoming “Fit for 55” legislative package 3. Improvement of the governance of pollution policies from Member States through the National Energy and Climate Plans and Ecodesign Please find enclosed the rationale behind our considerations.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe. Liquid Gas Europe wishes to share the LPG industry’s input on the preparation of the Renewable Energy Directive II (RED II) revision. The upcoming Commission’s impact assessment must consider all renewable fuels, including bioLPG, to foster their deployment. BioLPG, also known as bio-propane (RED II, Annex III), is a renewable gaseous fuel that provides up to 80% emissions reduction. Already available on the European market today in growing quantities, bioLPG is chemically and physically identical to conventional LPG. This allows the industry and consumers to seamlessly transition to a renewable solution. BioLPG can be ‘dropped-in’ to existing supply chains and can be used by consumers in their existing heating appliances or cars, stored in existing bulk tanks and cylinders, and transported using today’s infrastructure and skilled workforce. BioLPG offers a long-term, cost-effective pathway to reduce carbon and air pollutant emissions from hard-to-decarbonise sectors such as transport and rural heating. Already today Autogas (LPG in transport) has the potential to accelerate emissions reduction efforts from 250 million passenger cars on European roads. In rural areas, LPG undoubtedly can contribute to achieving the climate neutrality objective as there are around 40 million homes, and hundred thousands businesses, without access to the gas grid. We invite the European Commission to consider the hugely significant role of bioLPG in increasing the penetration of renewable gaseous fuels in both the European transport and heating sectors. To this end, the Renewable Energy Directive II should be amended to clearly include bioLPG. Please find enclosed the rationale behind our considerations.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe. Liquid Gas Europe wishes to share the LPG industry’s input on the preparation of the Energy Efficiency Directive (EED) review. We believe that the upcoming Commission’s impact assessment should focus on identifying measures to effectively implement the existing legislation. In rural areas, LPG condensing boilers, on their own, and hybrid systems represent inherently high energy-efficient solutions to keep warm homes that are not connected to the gas grid. They also offer a long-term, cost-effective pathway to decarbonisation through the gradual introduction of bioLPG into the energy mix. This renewable drop-in substitute reduces carbon footprint by up to 80% compared to conventional LPG. This means that over time carbon and air pollutant emissions from heat generation will increasingly reduce, improving the emission profile of a building, without having to resort to expensive future retrofitting of the heating system. It can be estimated that there are already over 2,000,000 LPG boilers in the EU that can lock-into lower CO2 emissions cost-effectively. To both reduce energy demand off the gas grid and increase the market share of renewable gases in the rural energy mix, we invite the European Commission to evaluate the following aspects of the Energy Efficiency Directive, improving the energy efficiency and the emission footprint of private and commercial heating: 1. A new Primary Energy Factor and its introduction in Ecodesign and energy labelling 2. Role of energy labelling in meeting the energy efficiency target 3. Emergence of technologies for sustainable heat generation Please find enclosed the rationale behind our considerations.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups composed of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe. Liquid Gas Europe wishes to share the LPG industry’s input on the roadmap for the Renovation Wave initiative. The upcoming initiative for the building sector is an opportunity to stimulate economic recovery and low-carbon transition by supporting European manufacturers, local economies and rural dwellers. In our feedback, Liquid Gas Europe would like to focus on the unique characteristics of the building stock and the heating energy landscape beyond the gas grid. There are around 40 million homes located in rural areas in Europe without access to the gas grid . The Renovation Wave initiative can facilitate their transition to more energy-efficient solutions, thus allow for reducing carbon and air pollutant emissions as well as lowering energy bills. To this end, the LPG and bioLPG industry invite the European Commission to consider focusing on the following aspects to be included in a broad strategy incentivising investment in improving the efficiency and the emission footprint of buildings: 1. Emergence of technologies for sustainable heat generation 2. Affordability and cost-efficiency of energy consumption 3. Heating solutions for rural communities Please see the attached document for rationale behind our considerations.
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Response to Strategy for smart sector integration

15 May 2020

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe. Liquid Gas Europe wishes to share the LPG industry’s input on the roadmap for the EU Smart Sector Integration Strategy. The upcoming strategy should recognise the unique characteristics of the building stock and the heating energy landscape beyond the gas grid. There are around 40 million homes, and hundred thousands businesses, located in rural areas in Europe without access to the gas grid , which can play a role in the integration of the European energy system. We invite the European Commission to consider the following elements for enabling the sector integration in rural areas: 1. Emergence of technologies for sustainable heat generation 2. Growing quantities of bioLPG 3. Closing the loop with the bioLPG production Please see enclosed the rationale behind our considerations.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

29 Apr 2020 · LPG use in Europe, potential of bio LPG, carbon neturality and specific challenges of rural regions in Europe

Response to Revision of the Energy Tax Directive

1 Apr 2020

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and renewable LPG in Europe. Liquid Gas Europe wishes to share the LPG industry’s feedback on the inception impact assessment of the review of the Energy Taxation Directive (ETD) which was published by the European Commission on Wednesday 4 March 2020. Liquid Gas Europe invites the Commission to consider the following additional building blocks to develop policy options for the upcoming review. The revised Directive should: 1. Take into consideration air quality and GHG emission impact of all energy products 2. Support alternative fuels with a track record of success 3. Align with measures tackling energy poverty and the transition to climate neutrality Please see enclosed the rationale behind our recommendations.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

9 Mar 2020 · Smart sector integration

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

19 Feb 2020 · European Green Deal

Response to Climate Law

5 Feb 2020

Liquid Gas Europe is a European association composed by national LPG associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and renewable LPG in Europe. The European LPG industry is committed to support the ambitious climate and energy goals set by the EU for 2050. We truly believe that LPG and renewable LPG, as clean-burning, versatile and resource efficient gaseous fuels are perfectly placed to help reaching these goals especially in rural areas and in road transport. Please find attached the detailed position of Liquid Gas Europe.
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Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

The DAFI helped growing the market for alternative fuels that had already reached a certain degree of maturity, such as LPG, and to jump start a market for newcomers (e.g. electricity). EAFO figures show that the number of alternative-fueled cars increased by 75% from 2008 to 2016, from 5,4 mil to 9,4 mil, improving the environmental performance of the car fleet. Despite this impressive growth, alternative-fueled cars in 2016 were only 3,6% of the total passenger car fleet, a big improvement from the 2,6% share in 2008, but still not enough to ensure that road transport is sustainable. On the positive side, big steps forward were made in terms alternative fuels' infrastructure. We believe that, while it is important to set long term goals, the EU should not forget solutions that are already available and can deliver significant benefits in the energy transition. LPG delivers big CO2 gains compared to conventional fuels: LPG vehicles emit 21% less CO2 than petrol and 23% less CO2 than diesel vehicles on a lifecycle basis (FQD). In addition, it also has great benefits in terms of pollutant emissions. RDE tests performed by European universities and research institutes showed that LPG cars emit up to 90% less PM than equivalent petrol models and 98% less NOx than similar diesel vehicles. Today, LPG significantly contributes to EU's climate and air quality agendas, as it's the most widely-used alternative fuel in EU, with 7,9 mil vehicles already on EU roads, with a network of 31,000 stations, ensuring that EU citizens are adequately serviced virtually anywhere in the EU territory. In the longer term, the LPG industry will continue delivering benefits in light of the EU 2050 CO2 targets. The hybridisation of Autogas vehicles allows to combine the benefits of electricity together with a longer range provided by a cleaner fuel. Moreover, renewable LPG has been recently launched on the European market. This novel product can reduce CO2 emissions by an additional 80%, compared to conventional LPG. To ensure that the market for AFs in Europe continues to flourish and to maximise the environmental contribution of these fuels, we urge European decision makers to continue looking both at the long and at the short term. Just promoting solutions that will be affordable and fit for mass-market only in the medium-long term means giving up on important short-term benefits, in particular related to air quality improvements. Air pollution is already cause of 400.000 premature deaths in Europe each year: not acting today would have an important death toll. Hence, we believe that continued support to gaseous fuels in transport is fundamental, as it will more quickly put Europe on track to reaching its climate and air quality goals. In addition, the EU should consider two measures having a great potential to further accelerate the improvement of the environmental performance of the car fleet. Firstly, the DAFI should not only deal with alternative fuel infrastructure, but it should also deal with vehicles. EU wide targets for alternative fueled vehicles would give the right signal to companies for investing in alternative fuels and to put clean vehicles on the market. Secondly, the DAFI should help solving the slow progress in improving the environmental performance of the car fleet, which is steadily aging. Cars in the EU in 2016 were on average 11 years old, up from 10.4 in 2013. This shows that many EU citizens keep using old, polluting vehicles, which is most probably linked to an affordability issue. Like the Energy Performance of Building Directive does with buildings, the Directive should promote solutions that can improve the environmental performance of vehicles, even when they are already on the road. Many engine retrofit options can help cutting emissions of the existing fleet at a reasonable cost, including converting conventionally-fuelled vehicles to LPG or other alternative fuels, and as such, should be supported
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Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

14 Mar 2018 · Mobility Package - Transport Infrastructure Development

Response to Evaluation Energy Taxation Directive

26 Sept 2017

AEGPL, the European LPG Association, welcomes the possibility to provide its feedback on the European Commission’s roadmap on the evaluation of the Energy Taxation Directive. Several pieces of EU legislation aim at making the EU economy more sustainable. The Clean Energy Package, currently under the scrutiny of the European Institutions, and pieces of EU legislation such as the Alternative Fuels Infrastructure Directive have as a goal to promote cleaner heating and transport fuels and solutions. The Energy Taxation Directive is a key policy tool that can and has helped the EU to pursue the climate and environmental goals also enshrined in the mentioned pieces of legislation, but can also pose insurmountable obstacles. Since taxation generally represents a large part of consumer energy prices, it is important that lower levels are granted to sustainable energy products, such as transport gaseous fuels, especially when those energy products represent a small part of the energy mix, otherwise this may make them unattractive for consumers. Currently, the Directive allows Member States to apply reduced levels to natural gas and LPG, when used in transport. Gaseous transport fuels have clear environmental benefits, which have been also recognised in the Alternative Fuels Infrastructure Directive. A wider uptake of alternative gaseous fuels could greatly help the EU to cut GHG and air pollutant emissions generated from the road transport sector. This would also generate important societal savings in terms of public expenditure related to healthcare costs. A study developed by TM Leuven using the TREMOVE model highlighted that, were LPG to reach a 10% share in the road transport energy mix, the total societal benefits resulting from the reduction in pollutant emissions would amount to over 5 billion euro.* Hence, we believe that, when evaluating the coherence of the ETD with environmental legislation (C.2 point 11), it would be important to also assess: - What consequences a variation of the rules on energy taxation for gaseous transport fuels would have in terms of market penetration - What would be the health costs or benefits consequent from a variation in the share of gaseous transport fuels in the transport energy mix, resulting from a variation in the excise level. - Whether any change to the EU minimum tax rates on gaseous fuels would undermine/contradict the objectives of the Directive on Alternative Fuels Infrastructure, and any other related EU policies. We will continue to collaborate with the European Commission, sharing the LPG industry's view on the Energy Taxation Directive. Should you have any questions, please do not hesitate to contact us. --------------- * AEGPL (2013), Autogas in Europe: the Sustainable Alternative, available online at http://aegpl.eu/media/81922/autogas%20roadmap%202013%20final%202mb.pdf
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Response to Fitness check of the EU Ambient Air Quality Directives

23 Aug 2017

Background The implementation of the Air Quality Directives certainly helped to contribute to the improvement of air quality in Europe. Both PM2.5 and PM10 emissions steadily decreased over the past 10 years. However, the European Commission found that, in 16 Member States, PM concentrations were still above the legal limits and has started infringement procedures against these countries. EEA data show that the commercial and residential sectors are the ones producing most particulate pollution in the EU. Their relevance has increased over the past 10 years, as in 2006, these sectors were responsible for 49% of PM2.5 and 36% of PM10 emissions, while in 2015 produced for 57% and 41% of total PM2.5 and PM10 emissions respectively. Hence, stronger action is required in these sectors. In the EU strategy on heating and cooling, the European Commission underlined that, in some countries, small scale residential heating with solid biomass is responsible for more than 50% of its annual PM emissions. Fuel switching to cleaner sources of energy, such as LPG, can greatly help to reach the EU goals. LPG is a clean burning fuel, producing almost no PM emissions. Moreover, despite significant improvements over the past few years, road transport is still responsible for roughly 10% of EU’s PM2.5 and PM10 emissions and for 40% of EU’s NOx emissions. Fuel switching to LPG can bring about great benefits also in this sector. A recent series of tests performed in real driving conditions demonstrated that an LPG car emits on average 90% less particles than the same car running on gasoline, and up to 98% less NOx than an equivalent diesel car(1). Section C.2. Issues to be examined Coherence Air quality legislation should be amended to provide a better picture of the composition of the PM emitted in the EU, as some of its components pose serious challenges. Black Carbon, for instance, has a high negative impact both on climate and health. Being a short-lived climate pollutant (SLCP), it has a relatively short lifetime in the atmosphere (a few days to a few decades), but its global warming potential over a 100 year time period exceeds that of carbon dioxide by a thousand times(2). Tracking the amount of Black Carbon emissions would allow to design policy measures that can also more effectively tackle climate change. Effectiveness The number of sampling stations should be increased, especially in rural areas. The current rules, set in Directive 2008/50/EC, require Member States to have, in rural areas, one sampling point for PM every 100.000 km2. This area is larger than the surface of 15 EU Member States. Evidently, sampling stations cannot currently provide accurate figures for air pollution in rural areas. In particular in rural towns, air pollution can be a significant problem, as not many clean heating fuel options are available. In urban areas, increasing the number of sampling points both for NOx and PM would be beneficial for municipalities planning to draw up measures aiming at cutting local air pollution, such as low emission zones. Efficiency When measuring the efficiency of the limits and of the measures set in legislation, not only the costs of the implementation of the Directives, but also the societal costs of inaction should be assessed. A study developed by TM Leuven using the TREMOVE model highlighted that, were LPG to reach a 10% share in the road transport energy mix, the total societal benefits resulting from the reduction in pollutant emissions would amount to over 5 billion euro(3). Relevance It is to be noted that WHO guidelines are being reviewed and that they may become even more stringent. The limits set in EU legislation should reflect those contained in the WHO guidelines to ensure that public health is protected. -- (1) https://tinyurl.com/rdeautogas (2) http://www.eib.org/attachments/thematic/short_lived_climate_polluants_report_2016_en.pdf (3) https://tinyurl.com/autogasroadmap
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Response to Annual energy statistics updates for annual and monthly energy statistics

2 Mar 2017

AEGPL, the European LPG association, welcomes the opportunity to provide its feedback on the Draft regulation amending Regulation (EC) No 1099/2008 on energy statistics, as regards the updates for the monthly and annual energy statistics. We believe that, in order to develop good policies, it is necessary to have good and relevant data. For this reason, we welcome the new draft regulation, which in many ways improves the classification of energy use. To mention one welcome improvement, the creation of subcategories for space heating, space cooling, water heating and cooking will certainly be useful in the development of policies related to the building sector. However, we believe that these subcategories should be mirrored in the commercial and public services category, in order to better understand the final energy use also in that sector. Align the definition of biogas to the one contained in the Renewable Energy Directive We think that the classification can be further improved, in order to facilitate the evaluation of existing and future policies. In particular, we believe that the definition of biogas contained in the annex of the draft regulation should be changed in order to align it to the one that has been proposed in the Renewable Energy Directive (i.e. “gaseous fuels produced from biomass”)1. Annex III of the Directive was changed, in order to include new gaseous biofuels that were not covered by the current Directive, but that are or are about to be on the market. Amongst these, there are bio-LPG and bio-propane, which will be launched on the market in the course of this year. Bio-LPG and bio-propane will be produced, inter alia, as a by-product of the production of biodiesel and through the fermentation of various types of biomass. The new annex III now covers several bio-LPG and bio-propane processes and the text of the Directive has been amended accordingly. AEGPL believes that the definition of biogas (3.5.8.2) in the draft regulation should be amended, as well, in order to reflect the text of the proposed Directive. Not doing so, Eurostat figures would not take into account the contribution of bio-LPG towards reaching the targets set in the Renewable Energy Directive. Introduce a “gas products” category We believe that the natural gas category, only covering natural gas for the moment, should be expanded in order to cover other products. We think that the best approach would be to amend the name of the category 3.2 into gas products and move LPG, ethane and NGLs in it. We think that this would better reflect the characteristics and the usage of these products, as they have more in common with natural gas than with the other oil products. For instance, LPG, when used as a heating fuel, satisfies the same consumers’ needs as natural gas, except that it is used in areas not reached by the natural gas grid. In transport, LPG is an alternative fuel like CNG. In terms of pollutant emissions, LPG has a similar profile as natural gas, while CO2 emissions are slightly higher, due to the different molecular composition (i.e. the higher number of carbon atoms). --------------------- 1. See COM(2016) 767 Art. 2 point qq
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