SEA\LNG LIMITED
SEA\LNG is a global, multi-sector industry coalition, created to improve the understanding of the environmental and commercial benefits of a marine fuel and the pathway it offers for decarbonisation through the use of its low and zero carbon alternatives, liquefied biomethane and liquefied e-methane.
ID: 920893436149-80
Lobbying Activity
Response to Sustainable transport investment plan
4 Sept 2025
Introduction SEALNG represents the full spectrum of the LNG maritime fuel value chainfrom producers and suppliers to shipowners, ports, engine manufacturers, and classification societies. This unique vantage point offers practical, technical, and commercial insights that are directly relevant to Europes Sustainable Transport Investment Plan (STIP), which aims to guide strategic investment in renewable and lowcarbon transport fuels across all modes, with an emphasis on waterborne transport and aviation. Core Principles We enthusiastically support STIPs goals of derisking private investment, boosting strategic autonomy, and strengthening technological leadership. To deliver effectively, it must: Ensure technology- and fuel-neutrality, enabling competition across pathways rather than pre-selecting winners. Leverage LNGs lower cost, immediate scalability, and critical role as a foundation for liquefied biomethane and emethane. Create a fungible, integrated market for alternative fuels, breaking down silos and enabling cross-use. Drive regulatory simplification, supporting the Commissions ambition to reduce reporting burdens by at least 25%, and avoid duplication with RED III, FuelEU, ETS and IMO frameworks. Key Recommendations 1. Align with Global Decarbonisation Frameworks STIP must align with the IMOs evolving GHG strategy to prevent duplicated burdens or conflicting incentives, and preserve EU competitiveness. 2. De-risk Scalable Fuel Investment STIP should prioritise investment mechanismssuch as FiTs, CfDs and mandates and indirect measures such as guaranteed grid connections that support scalable, cost-effective fuels. 3. Leverage Existing Infrastructure STIP should focus on utilizing existing interconnected gas infrastructure to support a scalable transportation and delivery system for liquefied biomethane and e-methane for maritime. This will require the acceptance of a mass balance chain of custody for these fuels across the EU gas grid. Liquefaction by equivalence must continue to be recognised as essential for biomethane and e-methane fungibility and infrastructure efficiency. This enables economies of scale using existing LNG terminals while maintaining supply security. 4. Reinforce Fungibility & Market Coherence Adopt an Omnibus framework to harmonize certification and reporting across fuels and transport modes, creating a Single Market environment that supports organic trading and innovation. STIP should support streamlined, globally aligned certification systems that reduce administrative load while preserving transparency and market integrity. 5. Reflect Market Momentum Real-world investment trends underscore LNGs central role: in H1 2025, according to DNV, 14.2 million gross tonnes of LNG-fuelled vessels were ordered, accounting for over 70% of all alternative-fuel tonnagea 78% increase over 2024. STIP should reflect this momentum by facilitating infrastructure and investment environments aligned with market dynamics. Conclusion STIP represents a pivotal moment to scale Europes maritime energy transition. By embedding neutrality, leveraging LNGs strategic advantages, and streamlining regulation, it can mobilise investment, reinforce global coherence, and accelerate decarbonisation. SEA-LNG stands ready to support the EU with expert input and collaboration. SEA-LNG 4 September 2025
Read full responseResponse to EU Ports Strategy
28 Jul 2025
EU Ports Strategy Consultation: feedback from SEA-LNG SEA-LNG highlights four key priorities to ensure ports effectively enable maritime decarbonisation and strengthen Europes industrial competitiveness: Fungible Market: We need a well-functioning Single Market for bio- and e-methane across maritime and related sectors, removing barriers to secure economic stability, regulatory certainty, and consistent certification and reporting. Technological Neutrality: The strategy must uphold technological neutralitybuilding on FuelEU Maritimeto drive innovation and fair competition across all decarbonisation pathways. But neutrality must not mean inaction: robust, science-based evidence demonstrates the LNG pathway is a credible, scalable route to net zero. Simplification an Omnibus Approach: A streamlined, integrated framework for the entire maritime fuel supply chain is essential. A single Omnibus initiative could reduce complexity and administrative burdens, aligning with the Commissions goal to cut reporting requirements by 25%, and 35% for SMEs, in this mandate. Maintain continuity with AFIR: It is vital to maintain consistency with the Alternative Fuels Infrastructure Regulation (AFIR), which requires core TEN-T maritime ports to deploy LNG bunkering facilities by end-2025. This recognises LNG as a key alternative fuel, ensures investment certainty, and supports the coordinated rollout of infrastructure needed to meet EU decarbonisation objectives. A Ports Strategy that builds on AFIR will secure the long-term framework necessary for alternative fuels to thrive across the EU.
Read full responseResponse to EU industrial maritime strategy
28 Jul 2025
EU Industrial Maritime Strategy: SEA-LNG feedback: Fungible Market We need a well-functioning Single Market for bio- and e-methane across maritime and related sectors. This means identifying and removing hurdles to ensure economic stability, regulatory certainty, and coherence in certification and reporting systems. Technological Neutrality We must uphold the principle of technological neutralitybuilding on the foundation laid by FuelEU Maritimeto foster innovation and fair competition across all decarbonisation pathways. But neutrality must not mean indecision: objective, science-based evidence consistently supports the LNG pathway as a credible and scalable option on the journey to net zero. Simplification an 'Omnibus' Approach A streamlined, integrated framework is needed for the entire maritime fuel supply chain. A single 'Omnibus' initiative could cut complexity and administrative burden, aligning with the European Commissions aim to reduce reporting requirements by 25%, and 35% for SMEs, during this mandate.
Read full response8 Jul 2025
Review of the EU Emissions Trading Scheme SEA-LNG submission Introduction SEA-LNG represents the entire LNG maritime fuel value chainfrom producers and suppliers to shipowners, ports, engine manufacturers, and classification societies, giving us a uniquely broad perspective on decarbonisations practical, commercial, and technical realities. This makes our views on the EU ETS especially relevant and constructive. In our response to the ongoing consultation, we stress the need to reassess the ETS in light of the IMOs evolving framework, ensuring coherence with a possible global market-based measure. It is crucial that regional measures like the EU ETS do not impose overlapping burdens that could undermine European trade competitiveness or duplicate what a global scheme can achieve more effectively. Ultimately, we advocate for the EU to champion a strong, unified global solution through the IMO that would render a separate EU ETS for maritime unnecessarydelivering decarbonisation in the most efficient, technology-neutral, and internationally aligned way. Coherence with a possible global market-based measure at IMO Reassessing the EU ETS in a global context With the IMO now setting more ambitious fuel intensity targets than the EU, there is a clear need to review how the EU ETS for maritime fits into this evolving international framework. It is vital that a regional system such as the EU ETS does not undermine or duplicate what can be achieved more effectively at a global level. Working towards a unified global solution Ultimately, the goal should be to secure a robust, EU-supported global scheme through the IMO that makes a separate EU ETS for maritime redundant. This would streamline compliance, avoid double regulation, and deliver decarbonisation in the most efficient, technology-neutral way. The EU should now focus on supporting effective global implementation and ambition-raising at IMO. About SEA-LNG SEA-LNG is a global, multi-sector industry coalition, created to improve the understanding of the environmental and commercial benefits of a marine fuel and the pathway it offers for decarbonisation through the use of its low and zero carbon alternatives, liquefied biomethane and liquefied e-methane.
Read full responseMeeting with Annika Kroon (Head of Unit Mobility and Transport) and EUROGAS and
24 Jun 2025 · Certification of Biomethane in Europe
Response to Revision of the Energy Tax Directive
7 Nov 2021
SEA-LNG Feedback on the Proposed Revision of the Energy Taxation Directive (ETD)
SEA-LNG
Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the benefits of LNG as a marine fuel throughout the entire value chain and the pathway it provides for maritime decarbonisation.
1. Summary
SEA-LNG is supportive of the proposal to set minimum tax rates on marine and other fuels based on both the fuel's energy content and environmental performance.
We understand that the revisions to the Energy Taxation Directive (ETD) is one of a basket of policy measures intended to address maritime greenhouse gas emissions in line with European Green Deal objectives.
We recognise that the proposed taxation rates, favour LNG as a marine fuel over traditional, oil-based marine fuels and that suggests that bioLNG and synthetic LNG (e-LNG) would not be disadvantaged against other renewable and low-carbon fuels maritime fuels. However, we have a number of concerns which if not addressed may significantly inhibit the ability of the measure to deliver on its objective and purpose.
SEA-LNG’s key concerns relate to:
• the need for all vessels to be treated equally;
• a lack of clarity regarding the application to international shipping;
• potential issues of coherence between the Revision to ETD and RED II and RED III; and
• the absence of clear definition of renewable and low-carbon fuels (RLF) in which bioLNG and synthetic LNG (e-LNG) should be explicitly included.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
7 Nov 2021
SEA-LNG Feedback on the Proposed Revision of Directive on Deployment of Alternative Fuel Infrastructure (AFIR)
SEA-LNG
Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the benefits of LNG as a marine fuel throughout the entire value chain and the pathway it provides for maritime decarbonisation.
1. Summary
SEA-LNG is pleased to see that LNG retains its status as a Transition fuel in the AFIR proposal and hence access to EU funding as well as the mandate and targets for LNG supply in maritime ports. This can facilitate the decarbonisation pathway offered by LNG, starting now and moving forward through the increased uptake of bioLNG and synthetic LNG (e-LNG).
We understand that the proposed revision of Directive on Deployment of Alternative Fuel Infrastructure (AFIR) is one of a basket of policy measures intended to address maritime greenhouse gas emissions in line with European Green Deal objectives. However, we have a number of concerns which if not addressed may significantly inhibit the ability of the measure to deliver on its objective and purpose.
SEA-LNG’s key concern relates to:
• a lack of clarity on targets for LNG bunkering infrastructure; and
• the absence of a clear definition of synthetic LNG (e-LNG) in the proposal.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
7 Nov 2021
SEA-LNG Feedback on the Proposed Amendments to the Renewable Energy Directive (RED III)
SEA-LNG
Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the benefits of LNG as a marine fuel throughout the entire value chain and the pathway it provides for maritime decarbonisation.
1. Summary
SEA-LNG fully supports the objectives of the European Commission to increase the EU-wide target for the use of renewable energy sources (RES) in transport for 2030 from 14% to 27-29%.
We understand that RED III is one of a basket of policy measures intended to address maritime greenhouse gas emissions in line with European Green Deal objectives. However, we have a number of concerns which if not addressed will significantly inhibit the ability of the measure to deliver on its objective and purpose.
SEA-LNG’s key concerns relate to:
• the absence of a Guarantee of Origin system - with certificates traded separately from the physical gas molecules – which will undermine market liquidity and hinder the ramp-up of renewable gases such as biomethane and synthetic methane (e-methane) and their liquefied equivalents bioLNG and synthetic LNG (e-LNG);
• the absence of clear definition of renewable and low-carbon fuels (RLF) in which bioLNG and synthetic LNG (e-LNG) should be explicitly included; and
• potential issues of coherence between FuelEU Maritime and RED II and RED III.
Read full responseResponse to Updating the EU Emissions Trading System
7 Nov 2021
SEA-LNG Feedback on the Proposed Revision of the Emission Trading System (ETS)
SEA-LNG
Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the benefits of LNG as a marine fuel throughout the entire value chain and the pathway it provides for maritime decarbonisation.
1. Summary
SEA-LNG is supportive of the revisions to the European Emissions Trading System (ETS), as one of a basket of policy measures intended to address maritime greenhouse gas emissions in line with European Green Deal objectives.
We understand that the proposed revision should favour LNG as a marine fuel over traditional oil-based marine fuels because of its lower carbon dioxide emissions. However, we have a number of concerns which if not addressed will significantly inhibit the ability of the measure to deliver on its objective and purpose.
SEA-LNG’s key concerns relate to:
• the fact that other important greenhouse gases such as methane and nitrous oxides are not in the scope of EU ETS; and
• the focus on tank-to-wake emissions only, which may lead to renewable and low carbon fuels such as bioLNG and synthetic LNG (e-LNG) being severely disadvantaged against fuels such as ammonia and hydrogen, if they are produced outside the EU from fossil fuels.
Finally, SEA-LNG strongly suggests that measures in the proposed revisions to EU ETS be co-ordinated with IMO to ensure that there is a level, global playing field for shipping.
Read full responseResponse to FuelEU Maritime
7 Nov 2021
SEA-LNG Feedback on the FuelEU Maritime Proposal
SEA-LNG
Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the benefits of LNG as a marine fuel throughout the entire value chain and the pathway it provides for maritime decarbonisation.
1. Summary
SEA-LNG fully supports the objectives of the European Commission to create a common EU regulatory framework to increase the share of renewable and low-carbon fuels in the fuel mix of international maritime transport.
We understand that FuelEU Maritime is one of a basket of policy measures with the intention of addressing maritime greenhouse gas (GHG) emissions in line with European Green Deal objectives.
We support the fact that the proposed policy measures are goal-based and technology neutral. In particular, FuelEU Maritime recognises the need for the GHG emissions intensity of marine fuels to be calculated on a Well-to-Wake basis and to include all major GHGs (carbon dioxide, methane and nitrous oxides). We recognise that the proposed legislation is supportive, in principle, of LNG and the decarbonization pathway it offers through bioLNG and synthetic LNG (e-LNG). However, we have a number of concerns which if not addressed will significantly inhibit the ability of the measure to deliver on its objective and purpose.
SEA-LNG’s key concerns relate to:
• the absence of clear definition of renewable and low-carbon fuels (RLF) in which bioLNG and synthetic LNG (e-LNG) should be explicitly included;
• the use of default only emission factors to calculate the emissions performance of fossil fuels versus default or actual and certified emission factors for renewable and low-carbon maritime fuels which is likely to be unworkable;
• issues with the methodology proposed to calculate the greenhouse gas intensities and associated emissions factors, in particular those relating to bioLNG and e-LNG;
• the determination of a reference value against which greenhouse gas intensity reduction targets are set which may penalise the most progressive companies which have already opted for lower carbon fuels;
• potential issues of coherence between FuelEU Maritime and RED II and RED III.
Finally, SEA-LNG strongly suggests that the measures proposed in FuelEU Maritime are co-ordinated with IMO to ensure that there is a level, global playing field for shipping.
Read full responseResponse to FuelEU Maritime
24 Apr 2020
SEA-LNG input to Inception Impact Assessment of FuelEU
SEA-LNG shares the EU’s climate neutrality objective by 2050. We also welcome the ambition to accelerate the achievement of low-emission, climate-neutral shipping and ports by promoting the uptake of sustainable alternative energy. We firmly believe that LNG in the maritime will be crucial in helping achieve these climate and air quality goals.
LNG is available: The Commission’s market report on 7 April 2020 states that for the first time, in Q4 2019 LNG became the second source of gas to the EU increasing by 42% year-on-year. DG ENER expects that global LNG markets are set to expand with new volumes entering the European market from US, Russia, the Middle East, Africa and Australia. (see GIINGL Annual Report 2020 for more details).
LNG is good for air pollution: The use of LNG improves air quality in urban areas and ports, offering an immediate answer to the sulphur cap adopted by the IMO. LNG’s sulphur (SOx) content is negligible (5 ppm max), e.g. 1,000 times lower than the IMO 0.5% rule, while other local pollutants, such as nitrogen oxides (NOx) are reduced by up to 95% and particulate matter by 99% compared with heavy fuel oil.
LNG as a fuel helps reduce greenhouse gas emissions (GHG): The independent Thinkstep study (attached hereby), commissioned by SEA-LNG and SGMF shows that GHG reductions of up to 21% are achievable from LNG as a marine fuel today, compared with current oil-based marine fuels over the entire life-cycle from Well-to-Wake (up to 28% Tank-to-Wake).
LNG is affordable: SEA-LNG study ‘LNG as a Marine Fuel – Our Zero Emissions Future Starts Now’ states that, even in demanding scenarios of LNG being strongly penalised due to environmental reasons, its price would be notably more stable and more competitive compared to the price uncertainty of other competing fuels. Moreover, under the assumption of a 10-year pay-back period, LNG as a fuel is the most economical option today and it can act as strong foundation for future reductions by using liquefied biomethane (LBM) and liquified synthetic methane (LSM) as the technology required continues to mature.
LBM and LSM are scalable: The recent study commissioned by SEA-LNG from CE Delft (attached) concludes that both LBM and LSM are scalable solutions for the maritime sector, with estimated sustainable global supplies potentially exceeding the demands of shipping in the future, and likely to be commercially competitive relative to other low- and zero-carbon fuels. See also IEA Outlook for biogas and biomethane.
Small-scale LNG infrastructure is expanding: The EU’s existing infrastructure provides sustainable and flexible logistic services in ports. These can be further leveraged by small-scale LNG services, including bunkering activities, to supply LNG to a growing number of LNG fuelled ships, provided investments in deploying LNG fuelled ships are accomplished. The number of LNG fuelled vessels increased from 96 in 2016 to 175 in 2019, with another 203 ships expected to be constructed by 2026. Bunkering infrastructure in Europe followed the trend with 131 installation offering bunkering services in 2019 compared to 113 in 2018. It is crucial that EU authorities continue to boost the LNG bunkering infrastructure for this positive trend to continue.
Methane slip was reduced by a factor of four since 1990s: Gas-fuelled engines were originally developed in the 1990s to address local emissions i.e. NOx and SOx. GHG emissions were not an area of focus at the time. Since then, the levels of methane slip, where applicable, have been reduced by a factor of four and engine manufacturers continue to invest in R&D with the aim to further reduce the amount of slippage (see the attached paper submitted to the IMO by SGMF). Hence, not only is significant abatement potential in selecting the proper engines among the available models, but the manufacturers are on a pathway to reduce methane slips even further.
Read full response