SHV Energy NV
SHV Energy is a leading global distributor of off-grid energy, such as LPG and LNG and is active in the area of sustainable fuels (bioLPG, bioLNG, rDME) and renewable energy solutions (energy efficiency, distributed solar).
ID: 292576015608-71
Lobbying Activity
Response to Heating and cooling strategy
8 Oct 2025
Renewable liquid gases (rLGs), such as renewable LPG and renewable DME, are sustainable drop-in alternatives to conventional LPG that cut lifecycle emissions by over 80% and work with existing infrastructure. They can play a crucial role in the energy transition by decarbonising heating in rural and off-grid areas where electrification is costly or impractical, while also contributing to cleaner industry and transport. With the right policy framework in place, Europes rLG supply can contribute significantly to a decarbonised and resilient European heating supply, improving the accessibility of the energy transition for rural and off-grid areas. To make this possible, we urge the Commission, through the Heating and Cooling Strategy, to: Explicitly recognise the role of renewable liquid gases in achieving a decarbonised heating sector, by acknowledging all available pathways and treating renewable liquid gases equal to other heating solutions in relevant follow-up legislation such as RED and ETD and get priority access to funding or incentives. Set a heating obligation mandating a share of renewable liquid gases within LPG consumption in the off-grid sector, to stimulate demand and unlock supply for accelerated adoption of renewable liquid gases. Bring clarity around the classification of renewable liquid gases to enable access to right feedstock and offer the necessary investment certainty to scale up supply pathways. Introduce robust yet flexible sustainability certification mechanisms to account for rLGs volumes through flexible allocation of sustainability credits derived from Proof of Sustainability (PoS) certificates in order to minimize administrative burden and associated costs.
Read full responseMeeting with Radan Kanev (Member of the European Parliament)
17 Sept 2025 · Alternative fuels
Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Liquid Gas Europe and
1 Jul 2025 · Decarbonisation of agriculture
Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)
19 Mar 2024 · energy priorities towards 2040
Response to Waste Framework review to reduce waste and the environmental impact of waste management
22 Nov 2023
SHV Energy is a leading global distributor of off-grid energy such as LPG and LNG and is active in the area of sustainable fuels (bioLPG, bioLNG, rDME) and renewable energy solutions (energy efficiency, solar). SHV Energy is a wholly owned subsidiary of SHV, a family-owned multinational, and consists of a group of specialised energy companies. We provide cleaner and lower carbon decentralised energy solutions to commercial and domestic customers in rural areas that are not connected to the natural gas distribution network. Together with UGI International, we established our joint venture Dimeta in February 2022. Dimeta focuses on advancing the production and use of renewable & recycled carbon dimethyl ether (DME), a low-carbon sustainable liquid gas which can be used to de-fossilise the hard-to-abate off-grid energy sector. rDME can be produced from a wide range of sustainable, locally sourced feedstocks including the non-organic fraction of municipal waste. Revision of the Waste Framework Directive Through waste incineration and recovery, waste is primarily deployed for electricity production. However, since electricity can be produced easily through abundant sources of renewable energy such as wind or solar, we do not believe electricity production is the most efficient usage of a carbon containing feedstock like waste. We believe directing waste towards the production of sustainable fuels, which are needed to decarbonize hard-to-abate sectors like off-grid heating, industry, and transport, is a more efficient use of the resource. In order to enforce this more efficient utilization of the waste resource, an ambiguity in the Waste Framework Directive should be cleared up. While advanced chemical recycling follows the definition of Recycling used in the WFD when waste materials are reprocessed into products, materials or substances whether for the original or other purposes, there is ambiguity regarding whether advanced biofuels and RCFs can be classified under recycling or recovery. It is very important for advanced recycling technologies deployments to be clarified as being recognised under recycling this is a key regulatory issue to help us tackle both decarbonisation and growing our circular economy in Europe, and will ensure that all non-recyclable waste diverted from landfills or incinerators will contribute to the recycling targets. Following this, we have identified two possible ways to clear up this ambiguity: 1. EU policymakers should modify the recycling definition in the WFD to include explicitly the production of advanced biofuels and RCF products from waste. 2. The Commission could offer assistance to Member States in assessing the assignment of specific technologies to different levels of the waste hierarchy. This could be done via guidelines for the interpretation of the requirements set out in the WFD. The production of advanced biofuels and RCFs should be mentioned explicitly as an accepted way of recycling. SHV Energy appreciates the opportunity to share its opinion and recommendations, and we remain committed to contributing to a green transition that works for all.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
22 Dec 2022
SHV Energy Introduction SHV Energy is a leading global distributor of off-grid energy such as LPG and LNG and is active in the area of sustainable fuels (bioLPG, bioLNG, rDME) and renewable energy solutions (energy efficiency, solar). SHV Energy is a wholly owned subsidiary of SHV, a family-owned multinational, and consists of a group of specialised energy companies. Our European brands include Primagaz, Calor Gas, Liquigas, Gaspol, Primagas, Butan Plin, PrimaLNG, SHV Gas Risk & Supply Management and EM3. With these companies, we make it our mission to provide decentralised, low-carbon and clean energy solutions to business and residential customers who are not on the energy grid. We encourage and enable customers to switch from the most highly polluting fuels, such as coal and heating oil, to LPG and LNG, which results in a significant reduction in carbon dioxide and particulate matter emissions. Response to the Consultation SHV Energy welcomes the recognition of the additional feedstocks in the proposed delegated directive but is concerned with the categorization of many of them as Part B feedstock, which will likely curtail investments and thus make it even harder to achieve our 2050 net zero targets. SHV Energy appreciates the effort invested in the process to develop a short list of feedstocks that qualify for inclusion in Annex IX under Tender ENER C1 2019-412, but it struggles to understand the need to categorize the feedstocks according to the associated technology maturity levels of production process. The distinction between Part A and Part B is primarily made on technology development status of processes that can produce biofuels and biogas. Part A is dedicated to advance technologies whereas Part B incorporates feedstocks that could be used with mature technologies. This distinction is not explained very clearly in the Commission proposal. The following impacts are foreseen: o Linking feedstocks to the development status of a technology would limit options for valorization of raw materials to produce biofuels and biogases. Feedstocks can be used across technological pathways irrespective of their development status. There are many feedstocks that are listed in existing Annex IX Part A of REDII that can be used in technologies that are fully mature such as anaerobic digestion. These feedstocks can also be used in technologies that are approaching full technical maturity or have entered near commercialization stage such as gasification. o The term advanced is often associated with the characteristics of feedstocks. Feedstocks that originate from non-food and feed crops are classified as advanced and the fuels that are produced as a result are termed as advanced biofuels and biogases. Whereas food and feed crops derived biofuels are first generation biofuels which have been in the market for quite some time and are produced using technologies that are technologically mature. The distribution of feedstocks between Part A & B based solely on technology maturity of different processes is causing confusion. o There are several feedstocks that are proposed to be placed in Part B which are currently understood to be included in broader Part A feedstock categories. Therefore, they are already accounted as advanced in many EU Member States. Putting them explicitly in Part B would mean retroactive changes to authorized biogas plants that are being constructed. o The proposal from the Commission has placed some of the feedstocks in Part B, which is currently subjected to 1.7% limitation or a cap in terms of contribution to the target of renewable energy share for transport in Art. 27 (1). This inappropriate placement would restrict the potential contribution of these feedstocks to the decarbonization objectives of the EU as they all of them should belong to Part A.
Read full responseMeeting with Franc Bogovič (Member of the European Parliament)
13 Sept 2022 · EPBD directive
17 Jun 2022
In the main text of the Delegated Act, paragraph 7, it is currently stated that for both RFNBOs and RCFs “capturing of emissions from non-sustainable sources should therefore only be considered as avoiding emissions until 2035”. We strongly recommend removing or amending this clause, for several reasons:
• This clause is likely to slow down the transition from low efficiency EfW to higher efficiency advanced conversion technologies. Investors will be unwilling to invest in waste gasification plants today which from 2036 will produce a significant portion of fuel that will be considered unsustainable.
• The date of 2035 is not in line with wider European policy for net-zero. The EU has committed to cutting emissions by at least 55% by 2030 and to achieve climate neutrality by 2050. Therefore by 2035 there will still be fossil carbon in the European economy which should be used in the most efficient way possible.
• We recognise the concerns of the Commission that production of RCFs or RFNBOs should not extend the lifetime of facilities producing non-biogenic waste. However in the case of municipal and industrial waste there is a complete disconnect between the demand for the waste for production of RCFs, and the production of waste by the individual. Therefore changes in RCF legislation are unlikely to impact the amount or biogenic content of the waste generated.
• A delegated act is not an appropriate piece of legislation in which to effectively phase out an entire category of fuels from a particular date. Such a decision, if taken, should be properly debated.
Annex A section 11, sub-section (a) currently excludes CO2 incorporated into a fuel that is taken from an energy from waste facility, because Energy from Waste is specifically excluded from Annex I of Directive 2003/87/EC. This exclusion means that no RCF or RFNBO produced from carbon sources diverted from an EfW facility will be able to meet the 70% threshold, even before 2035. This would seriously hamper the transition from low-efficiency energy from waste to high efficiency advanced conversion technologies because investments are unlikely to be made in plants for which a significant portion of the output is considered unsustainable.
We support the ambition shown in imposing a GHG threshold of 70% on RCFs. We note that under the methodology proposed the 70% threshold for RCFs will be challenging to meet in all but a few Member States because of the GHG intensity of their electricity grid. We suggest two changes which would enable more Member States to benefit from the decarbonisation potential offered by RCFs:
• A stepped increase in the GHG threshold for RCFs, starting from 65%, which is the threshold currently imposed on biofuels, and increasing by the late 2020’s to 70%. This would enable producers of RCFs to build plants in countries where grid CO2 emissions are falling rapidly, therefore allowing RCFs to easily meet a 70% threshold by the late 2020’s.
• Producers should be allowed to offset the “displaced” electricity, from diversion of non-biogenic waste from power production, with purchase of renewable electricity, following the principles established in the recent delegated acts to ensure the power is renewable and additional. This would allow plants producing RCFs to be constructed in all Member States, supporting member states GHG reduction targets and supporting the scale-up in renewable power generation capacity.
We believe that in line with the Innovation Fund GHG assessment methodology, the associated emissions from inputs whose ‘existing use or fate’ is landfilling, should be assumed equal to those for incineration without energy recovery because although landfill sequesters part of the carbon, encouraging landfills is not desirable for environmental reasons.
Finally, SHV Energy would like to request the inclusion of LPG in Annex B with standard values on GHG emission intensities of elastic fuels.
Read full responseMeeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)
16 Jun 2022 · EPBD
Meeting with Andreas Schieder (Member of the European Parliament, Rapporteur)
2 Jun 2022 · Exchange of Views EPBD
Meeting with Isabel García Muñoz (Member of the European Parliament)
18 Nov 2021 · Fit for 55
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
SHV Energy is a Dutch family-owned company and world’s leading LPG distributor, which also provides small-scale LNG, sustainable biomass and bioLPG for domestic heating, industrial heating, cooking and transportation. SHV Energy is also exploring opportunities offered by renewable DME and is working in several projects which includes collaboration with Oberon Fuels to accelerate the use of renewable DME to decarbonise transportation and beyond.
SHV Energy welcomes the revision of Directive 2018/2001 on the promotion of the use of energy from renewable sources (REDII) and as the distributor that brought bioLPG to the market in 2018, is pleased with the opportunity to share its feedback to the inception impact assessment. As part of its input SHV Energy covers bioLPG and renewable DME to inform the Commission’s upcoming impact assessment.
BioLPG, also referred to as renewable LPG, is the commercial name for biopropane (renewable propane) and biobutane (renewable butane) or the mixture of the two. BioLPG is a drop in gaseous fuel produced from biological or renewable sources. It is identical in use and performance to conventional LPG and has up to 80% lower carbon footprint. In addition, it shows the same untapped potential for air pollutant emissions reduction as LPG. Switching from an oil or coal boiler to an LPG one can reduce emissions respectively by 25% and 50%. Boilers relying on LPG emit 80-99% less PM and 50-75% less NOx than solid and liquid fuels boilers (such as coal, heating oil, peat, and biomass). On average, compared to diesel, Autogas emits almost no polluting particles and up to 20% less CO2 than petrol, measured under real driving conditions.
Renewable DME (rDME) also offers huge opportunities for near term decarbonisation, not only in transport sector but also in industrial and domestic heating and cooking applications. It is a sustainable gaseous fuel that can reduce greenhouse gas (GHG) emissions by more than 80% and significantly improve local air quality when substituted with diesel, heating oil and coal.
In the document attached you can find SHV Energy’s detailed feedback on the revision of the Renewable Energy Directive.
Read full responseResponse to Fitness check of the EU Ambient Air Quality Directives
22 Aug 2017
SHV Energy supports the European Commission’s initiative to undertake a Fitness Check of the EU Ambient Air Quality Directives. SHV Energy agrees that it is urgent to assess their relevance, coherence and effectiveness in addressing today’s most pressing air pollutants and setting meaningful air quality standards to protect human health and ecosystems, in accordance with the evolving scientific understanding.
To this end, SHV Energy believes that the review of the current regulatory framework should be based on the following key principles:
1. Coherent and holistic.
When it comes to assessing the role of energy production, the EU Ambient Air Quality Directives should be coherent with other EU legislation on transport, energy, and agriculture or nature protection and with international commitments, including the Paris Agreement on Climate Change. A holistic approach addressing both climate and health issues, should take into consideration all sources of pollution related to energy production and consumption and assess their relative impacts.
While the National Emissions Ceilings Directive entered into force on 31 December 2016 has established Emissions Limit Values for a number of pollutants, it has left a loophole in the regulation by failing to properly address Black Carbon (BC), which is formed from incomplete combustion. The main sources of Black Carbon are combustion engines (especially diesel), residential burning of wood and coal, power stations using heavy oil or coal, field burning of agricultural wastes, as well as forest and vegetation fires.
2. Based on the latest scientific evidence on Black Carbon.
The evolving scientific evidence has demonstrated that not all sources of energy have the same impact on climate and on health. However, some pollutants such as Black Carbon rank high in both aspects. A report carried out by the Regional WHO Office for Europe on the Health effects of Black Carbon provides sufficient evidence of an association of short-term (daily) variations in Black Carbon concentrations with short-term changes in health (all-cause and cardiovascular mortality, and cardiopulmonary hospital admissions), as well as sufficient evidence of associations of all-cause and cardiopulmonary mortality with long-term average Black Carbon exposure.
3. Provide right and complete information to the consumers.
EU consumers today are increasingly responsive to the impact of their market choices and want to be informed on how they can best contribute to protect the environment or fight against climate change. Buying a car or choosing a heating and/or cooking appliance is no longer a choice driven only by cost considerations and should be even less so in the future, if Europe aims at reaching its environmental targets. Providing the right information to allow consumers to choose cleaner energy sources should be a priority of the review of the current legislative framework.
4. Take into account outdoor and indoor environment, as well as urban and rural areas.
According to the WHO, Ambient (outdoor air pollution) in both cities and rural areas was estimated to cause 3 million premature deaths worldwide in 2012. Reducing outdoor emissions from household coal and biomass energy systems, agricultural waste incineration, forest fires and certain agro-forestry activities (e.g. charcoal production) would reduce key rural and peri-urban air pollution sources in developing regions. In addition to outdoor air pollution, indoor smoke is a serious health risk for some 3 billion people who cook and heat their homes with biomass fuels and coal.
Full feedback on the Fitness Check and more details on SHV Energy's key principles for the review of the current EU Ambient Air Quality Directives framework are available in the attached/uploaded Pdf document.
Read full responseMeeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)
29 Nov 2016 · Energy
Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)
18 Mar 2015 · Natural Gas