OG Clean Fuels B.V.

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OG Clean Fuels bezit en ontwikkelt tank- en laadinfrastructuur voor uitsluitend schone brandstoffen.

Lobbying Activity

Response to Clean corporate vehicles

8 Sept 2025

OG Clean Fuels welcomes the European Commission's proposal for a Regulation on Clean Corporate Vehicles. Please find our comments in the attached document.
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

10 Jun 2025 · Biofuels and transport decarbonisation

Meeting with Jens Gieseke (Member of the European Parliament) and TUI AG and Cummins Ltd.

4 Jun 2025 · Austausch zu EU Politik

Meeting with Esther De Lange (Cabinet of Commissioner Christophe Hansen)

4 Jun 2025 · Sustainable fuels

Response to EU Emissions Trading System - update of Verification and Accreditation Regulation (AVR), Batch 2

18 Apr 2025

OG Clean Fuels welcomes the European Commissions initiative to update the Accreditation and Verification Regulation (AVR) ((EU) 2018/2067) as part of the implementation of the EU Emissions Trading System (EU ETS) (Directive 2003/87/EC) to ensure consistency with the revised Monitoring and Reporting Regulation (MMR). Please see our recommendations for consideration in the feedback document.
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Meeting with Jens Gieseke (Member of the European Parliament) and TAXIS 4 SMART MOBILITY

20 Dec 2024 · Austausch zu EU Politik

Meeting with Auke Zijlstra (Member of the European Parliament)

24 Sept 2024 · E-Fuels

Response to Amendment to the CO2 determination regulation for heavy-duty vehicles

25 Jul 2024

OG Clean Fuels applauds the European Commission's initiative to update the methodology in Commission Regulation (EU) 2017/2400, aimed at determining CO2 emissions and fuel consumption for heavy-duty vehicles (HDV), to include those running on hydrogen and other emerging technologies and to improve the existing procedures. We strongly believe transparent and harmonised information empowers consumers and businesses to make informed and sustainable choices. We are also committed to advancing the adoption of clean and sustainable energy solutions. For this reason, OG Clean Fuels advocates for a technology-neutral approach, taking into account the entire lifecycle emissions and the full environmental impact of fuels. OG Clean Fuels supports a comprehensive methodology that equally evaluates all technologies, including alternative fuels such as biofuels. The current "tank-to-wheel" methods utilised in several EU road transport standards, such as Regulation (EU) 2023/85 and the revision of Regulation (EU) 2019/1242, are insufficient to accurately capture emissions throughout the entire process, from resource extraction to vehicle use. Biofuels offer a well-to-wheel green solution, effectively reducing emissions throughout their entire lifecycle.[1] Assessing the complete environmental impact of fuels ensures a fair and comprehensive comparison across all technologies. Commission Regulation (EU) 2022/1379 broadened the scope of Regulation (EU) 2017/2400 to include new technologies such as hybrid and pure electric vehicles. Research[2] indicates that well-produced biomethane can achieve greenhouse gas reductions comparable to battery-electric or fuel cell vehicles throughout their entire life cycle, from feedstock cultivation to final use. Compared to fossil fuels, biomethane demonstrably offers significant environmental benefits, encouraging its adoption as a clean fuel alternative. The widespread adoption of biomethane could yield numerous advantages: substantial reductions in greenhouse gas emissions, creation of new jobs, across the value chain, increased investment in renewable energy sources, and the ability for consumers to choose cleaner, potentially more affordable fuels. Additionally, biomethane production contributes to waste management and nutrient recycling, furthering the goals of a circular economy. Supporting these benefits also aligns with the EUs sustainability objectives. OG Clean Fuels therefore welcomes the introduction of a comprehensive methodology that not only effectively evaluates the CO2 emissions and fuel consumption of hydrogen-powered vehicles, and hybrid and electric vehicles (per Commission Regulation (EU) 2022/1379) but also considers new technologies such as alternative fuels, including biomethane. We advocate for the adoption of a robust, standardised lifecycle assessment to ensure a fair comparison of all fuels based on their true greenhouse gas impacts, promoting a level playing field across different clean transportation technologies. OG Clean Fuels stands ready to further clarify its position and collaborate with policymakers on this crucial matter. We are committed to driving the transition to a sustainable and low-carbon future and believe adopting a comprehensive, technology-neutral approach is crucial in achieving this goal. [1] Prussi, M., Yugo, M., De Prada, L., Padella, M. and Edwards, R., 2020. JEC Well-To-Wheels report v5. EUR 30284 EN. Publications Office of the European Union, Luxembourg. https://dx.doi.org/10.2760/100379. [2] Gustafsson, M., Svensson, N., 2021. Cleaner heavy transports Environmental and economic analysis of liquefied natural gas and biomethane. J. Cleaner Prod. 278. https://doi.org/10.1016/j.jclepro.2020.123535
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Response to Carbon footprint methodology for electric vehicle batteries

28 May 2024

OG Clean Fuels applauds the European Commission's initiative to establish a methodology for calculating the carbon footprint of electric vehicle batteries. We believe transparent and harmonised information empowers consumers and businesses to make sustainable choices. We are also committed to advancing the adoption of clean and sustainable energy solutions. For this reason, OG Clean Fuels advocates for a technology-neutral approach, taking into account the entire life cycle of batteries. OG Clean Fuels believes that a robust and standardised life cycle assessment (LCA) approach is crucial. The current "tank-to-wheel" methods utilised in several EU road transport standards, such as Regulation (EU) 2023/85 and the revision of Regulation (EU) 2019/1242, are insufficient to accurately capture emissions throughout the entire process, from resource extraction to vehicle use. A thorough LCA approach is therefore essential for fairly comparing various advanced biofuels, such as biomethane with electric drivetrains. The automotive market offers a variety of electric vehicle options, including battery electric vehicles with range extenders, hydrogen fuel cell vehicles, and plug-in hybrids. We hold the view that all these vehicles, along with biomethane-fueled options, should be evaluated using the same LCA methodology and assigned their respective carbon footprints. This inclusive approach ensures fair comparison across different clean technologies and highlights the environmental impacts of each option. Research suggests that well-produced biomethane can achieve greenhouse gas reductions comparable to battery-electric or fuel cell vehicles throughout their entire life cycle, from feedstock cultivation to final use. Compared to fossil fuels, biomethane demonstrably offers significant environmental benefits, encouraging its adoption as a clean fuel alternative. Widespread adoption of biomethane could unlock numerous advantages: substantial reductions in greenhouse gas emissions, creation of new jobs, across the value chain, increased investment in renewable energy sources, and the ability for consumers to choose cleaner, potentially more affordable fuels. Additionally, biomethane production contributes to waste management and nutrient recycling, furthering the goals of a circular economy. Supporting these benefits also aligns with the EUs sustainability objectives. OG Clean Fuels therefore welcomes the introduction of a comprehensive LCA approach that effectively evaluates not only battery electric vehicles with varying battery sizes but also range extenders, hydrogen fuel cell vehicles, plug-in hybrids, and biomethane-powered options. This will create a level playing field for all clean transportation technologies. OG Clean Fuels stands ready to further clarify its position and collaborate with policymakers on this crucial matter. We are committed to driving the transition to a sustainable and low-carbon future and believe adopting a comprehensive, technology-neutral LCA methodology is crucial in achieving this goal. 1.Gustafsson, M., Svensson, N., 2021. Cleaner heavy transports Environmental and economic analysis of liquefied natural gas and biomethane. J. Cleaner Prod. 278 https://doi.org/10.1016/j.jclepro.2020.123535
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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

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

11 Mar 2024 · Decarbonization

Response to Evaluation and revision of the Weights and Dimensions Directive

28 Nov 2023

OG Clean Fuels supports the Commissions initiative to revise Directive 96/53/EC. Hence, newly introduced flexibilities should not be limited to zero-emission vehicles only. A technology-neutral approach is needed, which should be inclusive of Internal Combustion Engine (ICE) trucks fuelled by hydrogen and advanced biofuels. Hence, the phasing-out date for using certain propulsion technologies for cross-border operations should be removed from the proposal.OG Clean Fuels encourages the inclusion of carbon-neutral fuels in the list of alternative fuels mentioned in the Directive. Directive 96/53/EC should not be more restrictive than Regulation (EU) 2019/1242 on CO emission performance standards and reporting obligations for new heavy-duty vehicles. OG Clean Fuels believes that the Directive should not phase out any propulsion technologies. According to research conducted by Gustafsson and Svensson, biofuels can be at least as good as battery-electric or fuel-cell drivetrains in terms of WtW climate performance. 2 With 100% biomethane, the WtW climate change impact is reduced by around 65% compared to fossil CNG, by 7075% compared to diesel, or by 95% compared to either of them with system expansion.Based on the above, OG Clean Fuels encourages the European Commission to take these considerations into account. Please find attached OG's position.
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Meeting with Markus Ferber (Member of the European Parliament, Shadow rapporteur) and Publyon

22 Nov 2023 · WDD

Response to Review of the CO2 emission standards for heavy-duty vehicles

19 May 2023

OG Clean Fuels is a pioneering company offering a diverse supply of clean fuels ranging from bio-CNG/LNG made from waste to green electricity and hydrogen available for every type of motor vehicle. As a leading business in the bio-CNG and LNG sector, OG advocates for the uptake of biomethane as transitional fuel in the road transport sector in Europe. OG Clean Fuels believes that a mere focus on electrification and hydrogen uptake does not provide a well-balanced solution to the challenges of the road transport sector. Heavy-duty long-haul transport is technically hard to electrify, as it requires high power engines able to cover long distances while carrying a heavy payload. Zero-emission technology is therefore developing much slower for HDVs compared to light vehicles such as cars. Currently, the limited availability of dedicated electric HDV charging locations, and the lack of existing parking spaces for trucks hinder installation of charging infrastructure. Moreover, the power grid will need strengthening to deliver the required power capacity. Promoting fleet renewal towards 100% zero-tailpipe emission HDVs, and thereby its complete charging/ refueling infrastructure, is uncertain. In the coming years, material scarcity of rare earth metals will likely drive-up prices for electric batteries and infrastructure even further. Sustainable mobility should not be measured by the type of drive - battery, electric or biofuels - but by the actual greenhouse gas savings over the entire life cycle. It is in the EUs best interest to provide a technology-neutral legislative framework for achieving the decarbonisation of this sector. Therefore, given the characteristics of the HDV sector, OG Clean Fuels views that the EU should focus on increasing the use of renewable fuels such as biomethane in revising the CO2 emission performance standards for heavy-duty vehicles (HDV CO2 standards). Why use Bio CNG/ LNG in in EU transport legislation? Biomethane, when used as a transport fuel, is a complementary solution to help the EU achieve its emission reduction goals. Biomethane is the cleanest energy carrier today and contributes to the circulare economy and is a complementary way to produce sustainable energy equal to wind, solar and hydroelectric power. The existing emission standards legislation, is based on a tank-to-wheel approach, only counts transport fuels emissions from the moment of refueling. However, in taking a well-to-wheel (WtW) approach, counting the transport fuels emissions from the moment of producing the fuel/energy carrier, biomethane represents one of the absolute lowest GHG intensive routes. This is concluded in a Science for Policy report by the Joint Research Centre (JRC), the European Commissions own science and knowledge service. For the revision of the HDV CO2 Standards Regulation, OG Clean Fuels proposes to: Take a technology neutral approach in EU policy on transport emission reductions because all alternatives to fossil fuels must be considered and to see Biomethane as complementary solution to EVs. We look foward exchanging views with policymakers on this file. Please find attached our visual position paper.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Publyon

12 Dec 2022 · to exchange thoughts on how to further position renewable fuels such as biomethane as part of the solution

Response to Monitoring of HDV on-road tests (VTP)

15 Mar 2021

Dear sir, madam, Thank you for facilitating the opportunity to give feedback on ‘CO2 emissions and fuel consumption of heavy-duty vehicles – results of on-road tests (delegated rules)’. Hereby our feedback. The key goal of this proposal is logical and clear. We support collecting data on emission-performances of heavy trucks in order to monitor its progress on CO2-reduction. However, data from on-road tests is based on a tank-to-wheel approach, that means: tailpipe emissions. This approach does not give a complete and holistic view of its CO2 performances. Instead, a well-to-wheel approach should be used. Such an approach gives insight in CO2-emissions among the chain from production of the energy source to the tailpipe.
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