Swedish Gas Association / Energigas Sverige
Increased role of gas (methane, LPG and hydrogen), and especially renewable gas, in society.
ID: 872104121716-69
Lobbying Activity
Response to Revision of the CO2 emission standards for cars and vans
10 Oct 2025
The Swedish Gas Association welcomes the Commissions efforts to decarbonize the transport sector. To ensure the success of this transition, The Swedish Gas Association stresses the need to implement a revision of the CO2 emission standards for cars and vans regulation that seeks a truly technology-neutral approach. This approach would allow for all climate-neutral solutions to contribute to the decarbonisation of the automotive industry, including the use of sustainable and renewable fuels, such as biomethane and hydrogen. Current CO standards are strongly biased towards tailpipe emissions, failing to acknowledge the full decarbonisation potential of the entire lifecycle of emissions coming from renewable fuels of biological origin that are compliant with the sustainability criteria laid out in the Renewable Energy Directive (RED). In fact, these fuels, such as biomethane, are not recognized in the current accounting system of the CO2 emission standards for cars and vans regulation, despite their proven ability to reduce lifecycle emissions significantly. Therefore, the Swedish Gas Association urges the Commission to consider in the upcoming review of the CO standards for cars and vans regulation the pivotal role of biogases and biomethane in being a complementary solution to electrification and a fully sustainable solution in line with the current framework of the RED. The Swedish Gas Association calls on the Commission to formally recognize CO neutral fuels as an integral part of the EUs road transport decarbonisation strategy. Without regulatory recognition, manufacturers, investors and fuel suppliers face a distorted market that focuses solely on the phase out of Internal Combustion Engine (ICE) vehicles without considering the opportunities of bolstering renewable energy sources such as biomethane. In fact, biomethane is a readily available, cost-competitive, dispatchable and compatible alternative to fossil fuels that can be used in ICE vehicles without the need for any retrofitting. Being compatible with existing infrastructure, biomethane can be injected into existing fueling stations for LNG and CNG without requiring further investments for additional infrastructure. When using a Well-to-Wheel methodology, which allows for a complete assessment of the environmental impact of a given fuel, biomethane is proven to be a high performer in terms of emissions reduction in transport. The lack of recognition for CO neutral fuels in the CO emission standards for cars and vans regulation is a missed opportunity for Europe to become energy independent, energy renewable and competitive. It is therefore of key importance to adopt a technology neutral approach towards all types of renewable fuels that are able to complement electrification and that can help reach the decarbonisation targets at scale. Complementary options, such as bio-LNG and bio-CNG, are immediately deployable, compatible with existing infrastructure (i.e. CNG and LNG stations), scalable through domestic feedstock supply chains, and offer opportunities for scaling up rural circular economies. The review of the CO emission standards for cars and vans regulation is an opportunity to ensure a transition that is both effective and sustainable.
Read full responseResponse to General revision of the General Block Exemption Regulation
3 Oct 2025
Kindly find attached Energigas Sveriges (The Swedish Gas Association´s) feedback for your consideration.
Read full response9 Jul 2024
The Swedish Gas Association welcomes the fact that the EU is taking an ambitious holistic approach to climate policy. The legislation package "Fit for 55" is an important step in reducing emissions by at least 55 percent by 2030, and achieving climate neutrality by 2050 two important goals that we fully support and stand behind. The EU's emissions trading system (EU ETS) and the renewables directive (RED) are two important regulations that lay the foundation for the transition. The Swedish Gas Association welcome the clear inclusion of RFNBO and RCF in the MRR rules. We also welcome the clear link to the RED definitions and sustainability criteria to be fulfilled to be zero-rated which should be done using a mass balance system. We welcome that it is clarified that the green gas concept or mass balance approach for biomethane co-distributed with natural gas in gas grids is expanded and valid to all sustainable gases including RFNBO and RCF, which means that the biomass/RFNBO/RCF-fraction of the gas is determined by purchase agreements and not analyses. We also welcome that it is clarified that proof of registration and withdrawal from the Union database can be used to determine the fraction of zero-rated carbon for biomass, RFNBO and RCF. In the newly adopted MRR guidance for ETS 2 very important rules was introduced that allow for mass balance approach to determine the biomass fraction in blended or co-distributed fuels. This is crucial and very much welcome. With that the ETS system is reflecting how the market works and can thus become an important steering instrument for increased share of fossil free fuels. All renewable or fossil gases uses the same infrastructure and distribution network - on grid or off grid, in gaseous form or liquid form. The possibility for co-distribution of fossil and renewable gases and allocation based on purchase agreements and proof of sustainability via a mass balance system is crucial for an effective gas market and for the transition of the user sectors to fossil free energy. As we interpret the ETS 2 guidance, this will be possible for gaseous fuels both on-grid and off-grid within ETS2. However, with this amendment of the MRR we expected a clarification that the fraction of zero-rated carbon may be determined by a mass balance approach according to the RED Article 30, allowing for blends and co-distribution of gases with different origin, and where the zero-rated fraction is determined and allocated to different users by purchase agreement and validated by the sustainability and mass balance system imposed by RED. Some of the new suggested paragraphs regarding RFNBO and RCF may be interpreted in such direction but clear provisions allowing for mass balance approach for all gaseous fuels both in ETS 1 and ETS 2 are still missing. The Swedish Gas Association urge for amendments in the MRR that clearly introduces a general possibility to use purchase agreements and the RED mass balance approach to determine the fraction of biomass fuels, RFNBO, RCF and low carbon gases (thus to determine the zero-rated fraction) both for ETS 1 and ETS 2 not only for gas grids but also off-grid. With the Union database (which will register all gaseous sustainable fuels including biomass fuels, RFNBO and RCF for any energy purpose) an extra layer of protection against fraud or double counting is added to the already robust certification and mass balance systems in place. Proof of sustainability complemented with Guarantees of origin is another way achieving the same certainty and extra protection against double counting. Please see attached document for our full reply.
Read full responseResponse to Review of the CO2 emission standards for heavy-duty vehicles
16 May 2023
We strongly welcome the intention of the EC proposal, i.e., to curb the GHG emissions from the heavy-duty road transport segment. However, it is of great concern that the proposal does not provide for a level playing field among technologies and favors a limited number of solutions, regardless of their footprint. Given the heterogeneity of the heavy-duty sector and the variety of aspects to be taken into account, no single technological solution or alternative low-carbon fuel will be sufficient, alone, to decarbonise the sector while safeguarding its competitiveness. Electrification, including hydrogen and e-fuels, will play an important role, alongside other clean technologies such as biomethane. With this in mind, we urge EU policy makers to recognize biomethanes valuable role as a long-term and cost-effective solution to ensure the decarbonization of the EU transport sector. The tailpipe approach in the CO2 emission standards encourages electrification and hydrogen but, unfortunately, it fails to encourage other clean technologies such as biomethane. The revised regulation should therefore introduce incentives for biomethane technologies, encouraging vehicle manufacturers to keep developing these technologies over time as tailpipe targets are being strengthened. Biomethane is one of the few readily available technologies truly capable of accelerating the segment decarbonization. It also stimulates vital investment and encourage environmental improvement in other industrial sectors such as agriculture and waste handling as a result of the additional benefits that biogas delivers: the recycling of plant and soil nutrients, reduced eutrophication, and improved biodiversity. Furthermore, production of biomethane and biofertilizer leads to socio-economic benefits such as improved security of supply, increased rural development, job creation, and promotion of innovation. Among alternative fuels, only biomethane has demonstrated, to date, such a deep and wide range of benefits to society. However, to untap biomethanes valuable role as a long-term and cost-effective solution to ensure the decarbonization of the EU transport sector, EU policy must be consistent and able to encourage the development of clean biomethane vehicles and technologies. As part of its REPowerEU plan, the European Commission set in 2022 a historical step forward for the biogas and biomethane sector: a 35 bcm target for the EU production of biomethane by 2030. This fundamental steppingstone towards the achievement of climate-targets, circular bioeconomy and supply security also implied the clear recognition of biomethane as a green vector necessary to achieve the EU clean energy transition. More recently, biogas and biomethane production technologies were accounted among the net-zero technologies (Article 2) and strategic net-zero technologies (Annex I and Article 10) in the Net Zero Industrial Act, which gives primacy to the supply of clean technologies. When looking at transport related legislation, the FuelEU Maritime and the Alternative Fuels Infrastructure Regulations clearly recognize biomethane as a renewable fuel that will progressively substitute fossil transport fuels. Moreover, the Renewable Energy Directive (RED) sets a transport combined target for advanced renewable fuels, such as biomethane, of 5,5%. The revision of the CO2 emission standards for heavy-duty vehicles should include consistent provisions with other piece of European legislation and it should recognise the role of renewable fuels such as biomethane as a key contributor to the climate objectives of the Union.
Read full responseResponse to Revision of EU rules on Gas
13 Apr 2022
The Swedish Gas Association welcomes the EU’s ambitious comprehensive approach to climate policy. The climate package “Fit for 55” is an important big step in reducing emissions by at least 55 per cent by 2030 and achieving climate neutrality by 2050 – two urgent targets that the Swedish Gas Association fully supports and stands behind.
The Commission’s initiative to review the EU’s gas regulations aims to remove unnecessary regulatory barriers to facilitate market access to renewable and low-carbon gases, thus helping to achieve the goals of the EU’s Green Deal. The Swedish Gas Association agrees that a fully functioning internal energy market is crucial to ensure security of supply, the energy sector’s competitiveness and energy at affordable prices.
Please see our answer to the Commissions consultation in attached file.
Read full responseResponse to Review of the CO2 emission standards for heavy-duty vehicles
14 Mar 2022
We welcome the initiative to review current CO2 emission standards for heavy-duty vehicles and to set more ambitious emission reduction targets for such vehicles. We also want to stress that EU legislation, including CO2 emissions standards regulation, should be built around research-based well-to-wheel or life-cycle analysis on climate emissions. The European Commission's own science and knowledge service, the Joint Research Centre (JRC), asserts that well-to-wheel analysis is required to properly assess the climate impact of different technologies. (https://publications.jrc.ec.europa.eu/repository/handle/JRC121213). On that basis, it is vital that a mechanism is introduced in the CO2 emission standards to include the contribution to CO2 emissions reductions from the use of advanced renewable fuels.
Under the current regulation, a manufacturer's compliance with its specific emission target is assessed only against the average tailpipe CO2 emissions of its fleet. We are very critical of this tailpipe approach. It is not recognizing the great contribution in emissions reduction achieved using biomethane and other advanced renewable fuels. It is an outdated and misguided approach that steers towards specific technologies rather than towards reduced climate impact and improved energy efficiency. The tailpipe approach is competition-distorting and far from technology neutral. It also misses its primary objective: to guide towards reduced climate emissions and away from fossil fuels.
The new initiatives within “Fit for 55” – FuelEU Maritime and RefuelEU Aviation – propose GHG intensity and well-to-wake calculations. We welcome this research-based approach. These initiatives also highlight very well the illogicality of persisting with a tailpipe approach in road transport policies.
When combining the tailpipe approach with very high or even a 100 % reduction target, sustainable alternatives such as biomethane will unfortunately be excluded from the market and denied the opportunity to contribute to the mitigation of climate change. That would be in sharp contrast to scientific findings (e.g. the Joint Research Centre mentioned above) showing that, from all combinations of fuel/energy carriers and powertrains explored, biomethane represents one of the absolute lowest greenhouse gas intensive routes.
In terms of the upcoming impact assessment, we particularly want to ask the Commission not to repeat the mistakes made in the impact assessment presented together with the proposed revision of the CO2 emissions standards for cars and vans in 2021. The Commission assessed that CO2 emissions, when measured under WLTP, would increase if a mechanism were to be introduced to account for renewable and low-carbon fuels. This is hardly surprising, since WLTP is based on a tailpipe measurement of emissions and thus does not capture the positive effects of renewable fuels. This means that the entire impact assessment was founded on completely unsound and unscientific premises. As a result, the crediting scheme and carbon correction factor (CCF) was dismissed far too lightly by the Commission.
Lastly, boosting biomethane production to 35 bcm by 2030 has recently been communicated by the EU Commission as an important REPowerEU measure to cut dependence on Russian gas. We welcome this long-awaited initiative, and we want to emphasise that the developing of growing biomethane markets will be an important step to foster the biomethane production scale-up. The CO2 emission standards will play a key role in that sense. If the emission standards were to be developed in a way so that they no longer encourage manufacturers to develop and offer heavy duty vehicles running on biomethane, we fear that it would hamper the REPowerEU plan to reach 35 bcm of biomethane production by 2030. Market development is an important part of boosting production, and biomethane needs to be acknowledged as an important part of the heavy-duty transport sector transition.
Read full responseResponse to Revision of the Energy Tax Directive
18 Nov 2021
The Swedish Gas Association – Energigas Sverige – welcomes a review of the Energy Tax Directive (ETD). The current ETD is an outdated directive from 2003 that does not reflect the EU’s climate goals.
We welcome the position taken in “Fit for 55” that regulations should work better together but it is a challenge that so many directives are being changed at the same time while also referring to each other. For example, please note that the proposed definition of biogas directly refers to the definition in the Renewable Energy Directive (RED), which is “biogas means gaseous fuels produced from biomass”. The term ‘biogas’ thus includes bioLPG and hydrogen gas derived from biogas or various types of biomass. It is important that this definition is not altered by revision of the RED.
The proposal aims to increase the share of renewable fuels derived from biomass or other renewable sources such as biogas, bioLPG and renewable hydrogen. The Swedish Gas Association is positive about this.
The current rules have not kept pace with the development of alternatives fuels, such as hydrogen. Additionally, the true value of the minimum tax rates determined in the Directive have declined over time, because they have not been indexed against inflation. The Swedish Gas Association agrees that change is necessary and supports the new structure and design of the minimum tax rates that the Commission has proposed.
It is positive that proposed minimum tax rates are based on the energy content and environmental performance of various fuels and electricity, rather than by volume as is most common today. Since biofuels generally have lower energy content than fossil fuels, and because their taxation has been set om the same level as their equivalent fossil fuels, this has meant that biofuels have been taxed higher than their fossil fuels equivalents.
The Swedish Gas Association also agrees that minimum tax rates, lower than for the fossil fuels, should be introduced for fuels based on biomass or other renewable fuels. This logic enables a favourable taxation of sustainable biogas, bioLPG and renewable hydrogen, without taking the form of state aid. It provides a better basis for long-term and predictable taxation.
Both natural gas and biogas are largely composed of the same gas (methane) and they are often distributed together. The same applies to bioLPG and LPG, and hydrogen from different sources. Co-distribution of this kind will be a major challenge in the taxation system. Bear in mind that methane with three different minimum tax rates probably will be distributed together and blended in the gas grid. The same situation will occur for LPG and hydrogen. It is important that a GO:s (guarantees of origin), mass balance etc is accepted in the taxation. It is not reasonable or effective to distribute renewable fuels separately – with negative economic and environmental consequences – in order to reach the tax advantages they are entitled to. This must be valid both for distribution and for storage.
The Swedish Gas Association is also, in principle, positive about the proposed categorisation and ranking of fuels, based on their environment performance.
It should be clarified that the lowest minimum tax rate also is applicable for renewable hydrogen produced from biogas or biomass, and not only for renewable hydrogen from non-biological origin.
The Swedish Gas Association finds it remarkable that electricity is included in the lowest minimum tax rate category, regardless of how it is produced. We believe that electricity produced from fossil sources should not be included in this category.
We are pleased to note that the Commission recognises the important role that natural gas, LPG and fossil hydrogen can play in paving the way towards renewable alternatives. This is indicated by the lower minimum tax rate proposed to apply to transitional fuels for 10 years.
For more detailed comments on article 2, 5, 15, 22 and annex I, please attached annex.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
18 Nov 2021
The Swedish Gas Association welcomes an ambitious expansion of infrastructure for electric and hydrogen vehicles, but we believe that biomethane should be addressed with the same level of ambition. This is not the case with the Commission’s proposed regulations, even though biomethane is one of the market’s most sustainable and cost-effective alternative fuels. The Swedish Gas Association wishes to emphasise the importance of taking cost-effectiveness into account when EU member states negotiate an agreement on the goals for infrastructure development.
The Swedish Gas Association is convinced that the only way of achieving a quick and cost-effective decarbonisation of road transport is to support all existing solutions, including biomethane (both in compressed and liquified forms – bioCNG and bioLNG).
The EU should also strive for technology neutrality in policies. With the proposed regulation, the Commission has unfortunately taken a step in the wrong direction in this matter.
It is good that the new regulations clarify that there is a range of both renewable and fossil-based alternative fuels. On the other hand, it is completely unacceptable that electricity, hydrogen and ammonia do not follow the logic applied to other alternative fuels, that is, categorisation into renewable and fossil fuels.
It is a very positive development that the regulation points more unambiguously (relative to the current directive) towards “a clear decarbonisation pathway” for gaseous and liquid fossil fuels. However, we note that a similar reasoning has not been applied to electricity and hydrogen as fuels.
Battery and fuel cell vehicles are described as “zero-emission powertrain technologies”, without any reference to or reflection on how electricity and hydrogen would be produced. The notion that electricity and hydrogen would, by definition, produce "zero emissions" is a major shortcoming in EU climate policy in general, and it risks complicating, hindering and delaying decarbonisation of the transport sector. It is self-evident that if electricity and hydrogen are produced from fossil sources, then CO2 emissions will be released.
All these elements should have been better taken into account in the European Commission’s proposal and related infrastructure targets.
Finally, as always, when new fuels are put on the market, it is also of the highest importance that safety is prioritised when infrastructure is expanded. This is equally relevant to electricity as it is to hydrogen and other alternative fuels.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
12 Nov 2021
The Swedish Gas Association – Energigas Sverige, the industry organisation in Sweden – is thankful for the invitation to contribute comments on the Commission’s revision of the Renewable Energy Directive (hereafter called RED III), 14 July 2021.
The Swedish Gas Association has only had a short time to examine the proposal, and thus has only been able to analyse it a limited amount of detail. It is also difficult to ascertain how RED III interacts with other proposals within the “Fit for 55” package and to assess the combined result. A deeper impact assessment of the combined effects of the proposals is required.
Summary
The Swedish Gas Association is positive about the increased ambition around renewable energy and the EU’s more stringent binding targets. However, we are doubtful that the introduction of increasingly detailed regulations and sub-targets for different types of energy and sectors will help to meet these targets. The proposal is equally likely to increase administrative requirements, complicate the use of national instruments, and prevent the application of cost-effective market solutions.
We are strongly critical of the Commission’s proposal for a series of provisions for more stringent sustainability criteria for bioenergy – forest biomass in particular – especially since the sustainability criteria established in the 2018 in RED II have yet to be implemented in many places across Europe. This risks further inhibiting sustainable bioenergy and making it more expensive.
The Swedish Gas Association also sees risks in the Commission’s proposal to use delegated acts to decide on certain provisions, potentially long after the Directive goes into force. This makes it nearly impossible to know the implications of certain goals and regulations, and it offers stakeholders little opportunity to influence the Directive. We also ask that different renewable fuels and types of energy be treated and valued equitably in RED III, as well as in other legislation, by applying life-cycle analysis evenly, with reference to actual conditions.
The Swedish Gas Association also believes that both the ambiguities of the Union database and its potential to benefit only specific fuels are so substantial that it should not be extended to cover all sustainable gases. Instead, renewable gases should be completely removed from the database until a comprehensive solution can be delivered, with a fully-developed, functioning system of guarantees of origin (GO). As an alternative, GOs could be used until the point of delivery to the end customer, and only at this time (when the GO would be cancelled) should it be necessary for the gas to be registered in the Union database. We also oppose the Commission introducing additional requirements through delegated acts.
For further and detailed comments, please see our Annex included.
Read full responseResponse to Updating the EU Emissions Trading System
8 Nov 2021
The Swedish Gas Association supports the Commission's proposal to revise the EU ETS so that the regulations are in line with the goal of reaching net greenhouse gas emission reductions of at least 55% compared to 1990 levels, by 2030.
According to the stated proposal, the combustion of biofuels will continue to be assigned an emission factor of zero, and will therefore not be affected by emission allowance costs. We agree with this approach, and share the Commission’s view that it incentivises fuel suppliers to sell biofuel, thus increasing its market share and reducing the usage of fossil fuels. However, it is apparent that the proposals in the "Fit for 55" package are not coordinated, because the Commission, in the proposal on CO2-standard regulation, recommends that biofuels and biogas should be classified as fossil fuels, which would phase out the use of biofuels. These proposals are patently incompatible.
The Swedish Gas Association agrees that maritime transport, as with other sectors, needs to switch to a more sustainable fuel mix. Gas has a significant role to play here. When applied to conventional technology, switching from marine bunker oil to liquefied natural gas (LNG) sees shipping companies reduce CO2 emissions by at least 10-20% and reduce emissions of nitrogen oxides (NOx) by as much as 85-90%. Problematic sulphur and particulate emissions are cut to almost zero. Additionally, an advantage of changing from marine bunker oil to LNG is the potential to gradually replace fossil-based gases with renewable gases. We consider it positive that the Commission intends to work to provide the maritime industry with a better basis to enable them to switch to sustainable fuels.
It is, however, important that the proposed instruments are analysed carefully, both with regard to their efficiency and with consideration to the competitiveness of the shipping industry. This is especially so as the Commission, within the “Fit for 55” framework, proposes that multiple parallel instruments will be applied (tax, stricter GHG intensity limits etc). The Swedish Gas Association calls for a coherent analysis of their impact on the shipping industry’s competitiveness.
If it is decided that road transport and the building sector will, in fact, be included in the EU ETS, the Swedish Gas Association agrees to that this should be done through a separate trading system. With the same proviso, we also support the view that the new system should be aimed at fuel suppliers (as they already are liable to pay tax) rather than households and car drivers.
In Article 10a the proposal states that installations covered by the obligation to conduct an energy audit under the Energy Efficiency Directive must implement the audit’s recommendations, to the extent that the pay-back time for the relevant investments does not exceed five years. Otherwise, their free allocation of emission allowances shall be reduced by 25%. The Swedish Gas Association does not believe that energy efficiency should be linked to instruments for reducing emissions. When regulations with different purposes overlap in this way, there is a risk that the cumulative result will be ineffective. It is not clear that emissions and energy efficiency measures always lead in the same direction – a measure to reduce emissions can, in some cases, even lead to an overall increase in energy use. We therefore contend that the proposal relating to energy efficiency measures should be deleted.
In Annex I the Swedish Gas Association considers it inappropriate that a threshold value of 95% bioenergy use is proposed (see Annex I) for free allocation of emission allowances. This gives a signal that only 95% of fossil fuels should be phased out rather than 100%. The share of fossil fuels in the Swedish district heating industry was approximately 1% in 2020, meaning that Sweden already has the lowest proportion of fossil fuels in its heating sector in the EU.
Read full responseResponse to FuelEU Maritime
8 Nov 2021
The Swedish Gas Association – Energigas Sverige – considers the proposal to be basically well-designed and is generally positive about it. We also believe that the proposed rate of reduction of greenhouse gases appears appropriate, in light of the climate targets set up by the EU.
We welcome clear rules and requirements because they eliminate doubts and uncertainties. We are glad that the proposal is designed to pursue technology neutrality, and that it focuses on greenhouse gas intensity.
The Swedish Gas Association has, however, a few comments and questions that we believe need to be addressed in future negotiations:
• Greenhouse gas emission calculations for assessing climate and environmental impact should take the complete scope of emissions into account, rather than using so-called “tailpipe” calculations. The Commission's proposal states that a “well-to-wake” perspective should apply, capturing the climate and environmental impact of fuel production and usage. We believe this to be a good approach. However, against this background it is stated that emissions from electricity are zero (see Annex I). This is completely misleading and, in practice, undermines claims of technology neutrality. It is important to remember that over 40% of electricity generated in the EU each year derives from fossil fuels. An emissions factor of zero in respect to emissions from electricity is, therefore, totally unacceptable.
• In the FuelEU Maritime proposal, the Commission refers in several places to other directives that are subject to revision as part of the “Fit for 55” legislation package. This means that the impacts of the FuelEU Maritime proposal cannot be assessed individually, as they would be completely dependent on whether and how changes are enacted in other directives.
• In the proposal, the Commission also refers to the calculation of emission factors with reference to the Renewable Energy Directive. It is therefore of the utmost importance that the ongoing revision of the Renewable Energy Directive does not lead to changes in the methodology for calculating emission factors that could, in turn, lead to reduced opportunities for conversion to renewable fuels in the shipping industry. The Swedish Gas Association believes that the proposal should clarify how emissions from biofuels are calculated. In Annex II, Table 1, Column 6, the emission factor should be amended to match the calculation in the Renewable Energy Directive, i.e. zero, or with a note (*) explaining that emissions are calculated according the Renewable Energy Directive.
• We believe that the proposal partly penalises those shipping companies that invested early in environmentally sound technology, since they have already taken measures to reduce greenhouse gas emissions. Several shipping companies have invested in ships that run on liquefied gas, and the proportion of biogas in these fuels is expected to rise in the future, see below. Since the depreciation period for ships is often 30 years or more (compared to around seven years for a goods lorry, for example), this should be taken into account in the ongoing work on the proposal.
• As the proposal is a part of a larger legislation package, it is of great importance that it is coordinated with other relevant proposals. Some examples are the ongoing review of the Energy Taxation Directive (ETD) and the Emissions Trading System (EU ETS.) In addition, the Directive on alternative fuels infrastructure (AFIR) and the Renewable Energy Directive (RED II) are relevant. The proposal should also be aligned with the International Maritime Organisation (IMO).
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
8 Nov 2021
We welcome strict requirements in the EU’s CO2 emission performance standards, but we believe that EU legislation should be built around research-based well-to-wheel or life-cycle analysis on climate emissions.
We are very critical of the persisting with the tailpipe approach, as proposed by the Commission. This is an outdated and misguided approach that steers towards specific technologies rather than towards reduced climate impact and improved energy efficiency. The proposal is competition-distorting and is far from technology neutral. It also misses its primary objective: to guide towards reduced climate emissions and away from fossil fuels.
One consequence of the proposal is that renewable, sustainable alternatives, such as biomethane, are excluded from the market and denied the opportunity to contribute to the mitigation of climate change. It is in sharp contrast to REDII and scientific findings showing that, from all combinations of fuel/energy carriers and powertrains explored, biomethane represents one of the absolute lowest greenhouse gas intensive routes (https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-reports/jec-well-wheels-report-v5).
The European Commission's own science and knowledge service, the Joint Research Centre (JRC), asserts that well-to-wheel analysis is required to properly assess the climate impact of different technologies. Basing policy objectives and instruments on tailpipe emissions only, as the Commission proposes, is contrary to research recommendations.
The new initiatives within “Fit for 55” – FuelEU Maritime and RefuelEU Aviation – propose GHG intensity and well-to-wake calculations. We welcome this research-based approach. These initiatives also highlight very well the illogicality of persisting with a tailpipe approach in road transport policies.
The crediting scheme and carbon correction factor (CCF) have been dismissed far too lightly by the Commission. It is vital that such a mechanism be introduced so that a more accurate and technology neutral assessment of climate impact can be incorporated in the CO2 emission performance standards.
In terms of environmental impact, the Commission ascertains that CO2 emissions (when measured under WLTP) increase with the CCF option. This is hardly surprising, since WLTP is based on a tailpipe measurement of emissions and thus does not capture the positive effects of renewable fuels. This is remarkably careless; in fact, it means that the entire impact assessment is founded on completely unsound and unscientific premises.
We are convinced that all renewable and sustainable alternatives are needed to cope with the immense challenge of climate change and to reach our common environmental goals. There is not a single solution that can replace petrol and diesel as used today. Biomethane (biogas), renewable hydrogen, renewable electricity, and other renewable and sustainable alternatives are all necessary.
Finally, replacing petrol and diesel with biomethane would not only benefit the environment and mitigate climate change directly. It would also stimulate vital investment and encourage environmental improvement in other industrial sectors – such as agriculture and waste handling – as a result of the additional benefits that biogas delivers: the recycling of plant and soil nutrients, reduced eutrophication, and improved biodiversity. Furthermore, production of biogas and biofertilizer leads to socio-economic benefits such as improved security of supply, increased rural development, job creation, and promotion of innovation. Among alternative fuels, only biogas has demonstrated, to date, such a deep and wide range of benefits to society.
The Commission’s proposal based on tailpipe emissions hampers any efforts to advance biogas for mobility. Hence it also prevents the EU from taking advantage of all the cost-effective solutions that biogas has to offer in the transition to a sustainable society in a broad perspective.
Read full responseResponse to Revision of EU rules on Gas
10 Mar 2021
It is important that the EU- regulation help and not risk hindering the EU Member States to reach energy, environmental and climate goals. In line with the Green Deal Strategy, energy markets will need to transform to enable moving towards a net zero target, and it is important that these objectives can be realised in a non-disruptive and cost-effective manner. The Swedish Gas Association welcomes this roadmap/inception impact assessment but would like to bring forward some important aspects in this context.
Please note, that the wording biogas in our text below, include both biogas and biomethane.
In the communication from the EU-Commission, the gas grid in Europe often is described as a fossil infrastructure. The Swedish gas association would like to take the opportunity to underline that the infrastructure itself is not fossil, but the gas that is distributed through the grid can be either fossil (natural gas), renewable (biogas) or a mixture of natural gas and biogas. The situation is the same for the electricity grid. Just as fossil gas and renewable gas (or a mix of them) can be distributed via the gas grid, both fossil and renewable electricity can be transferred via the electricity grid. But we have not heard anyone call the electricity grid a fossil infrastructure. It is important to understand that we are talking about one and the same infrastructure for both biogas and natural gas, not one for natural gas and another for biogas. The gas grid is a network that creates good and energy effective conditions for distribution of gas, both fossil and renewable. In fact, the gas grid is needed for the industry, shipping, transport and other areas of use to be able to switch to renewable gas.
Different types of steering instruments will determine if fossil or renewable gas is demanded and thus distributed via the same gas grid. But the gas net itself is not fossil, it is just a distribution system that provides the opportunity to distribute the gas that is in demand.
The EU-Commission has in different contexts stated that the ambitious EU Climate ambition requires effective carbon pricing and the removal of fossil fuel subsidies and other state aid to fossil fuels. The Swedish Gas Association agrees that well-designed steering instruments play a direct role by sending the right price signals and providing the right incentives for sustainable practices of producers, users and consumers. But regarding state aid to fossil fuels, the Swedish Gas Association wants to emphasize that natural gas and LPG is necessary in a short- and mid-term perspective to create and maintain a competitive market for biogas and bio-LPG, including an extensive increase in production of renewable gas at a competitive price. Furthermore, the use of natural gas and LPG will in some sectors continue to be an important precondition of the competitiveness of the European Community, for example in industry and transport. A good example where fossil gas paves the way for renewable gases is gas used as motor fuel in Sweden. The proportion of biomethane in gas used as motor fuel has continuously increased in recent years and 2019, the proportion was 94 percent. In the first half of 2020, the share has increased even further and now amounts to 95 percent!
Please see our attached document to read our views in full.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
We welcome the efforts to engage the financial sector to invest in the transition to a carbon neutral economy. However, the draft proposal is clearly not in line with the overall political and legal framework that recognizes the important role of biogas in sector integration, circular economy, decarbonization of transport and other sectors, reducing methane emissions in agriculture and waste management. Criteria proposed in especially Annex 1 raise some urgent concerns (please see also attachment):
Biogas and other forms of bioenergy (4.8, 4.13, 4.20, and 4.24)
In the draft, biogas and other forms of bioenergy are noted as ‘transitional’ activity without considerations to the whole value chain and without due scientific explanations. This is in sharp contrast with REDII (2018/2001) – adopted by the EU’s ordinary legislative procedure and currently under implementation in the Member States – where specific criteria are set for bioenergy to be sustainable.
Especially biogas offers solutions to several long-term challenges: climate, soil fertility, clean water, and good air quality. Biogas turns a waste problem into a resource. Scientific findings show that biogas contributes, directly or indirectly, to every one of the 17 UN Sustainable Development Goals (http://liu.diva-portal.org/smash/get/diva2:1161103/FULLTEXT01.pdf).
Qualifying sustainable biogas as a ‘transitional’ activity, even if it complies with sustainability criteria of RED II, is certainly not justified. It would severely hamper investments in sustainable biogas solutions with multiple benefits, thus, go against the objectives of the EU Green Deal.
Recommendations:
Remove the word ‘transitional’ in all references to biogas and other forms of bioenergy complying with sustainability criteria in REDII. Sustainable biogas should be encouraged and considered as enabling activity, regardless of end use.
Activities related to transport, vehicles, and vessels (3.3, 6.3, 6.5-6.12, and 6.15-6.16)
The absence of Life Cycle Analysis of the transport related activities does not provide with the real performance of mobility solutions in terms of GHG emission reductions. This creates an uneven playing field where so called ‘zero emission’ options (tailpipe) are systematically considered as sustainable, independently from the origin of the energy and emissions related to battery production.
This technology-biased approach excludes the use of sustainable biomethane in transport from the scope of climate change mitigation activities, both from the vehicles, vessels and refuelling infrastructures standpoints. This is in sharp contrast with REDII and with article 10(1) of EU 2020/852 stating: “An economic activity shall qualify as contributing substantially to climate change mitigation … by: (a) generating, transmitting, storing, distributing or using renewable energy in line with Directive (EU) 2018/2001”.
It is also in sharp contrast to the scientific finding of the JRC, the European Commission’s science service providing evidence-based support to the policy making process (https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-reports/jec-well-wheels-report-v5). The JRC studies conclude that, from all combinations of fuel/energy carriers and powertrains explored, biomethane represents one of the absolute lowest greenhouse gas intensive routes. The climate benefits of using biomethane are, according to the study, similar to the use of renewable electricity. Even significant negative emissions can be derived from routes involving biogas or biomethane from manure.
Recommendations:
Consistently apply a Life-Cycle Analysis to set TSC for all transport activities to create a consistent level playing field that supports all available solutions to decarbonise transport. The TSC for activities linked to transport, vehicles and vessels should align with the Annex IX of the REDII to include biomethane used in transport in the climate change mitigation activities.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
26 Nov 2020
The EU has committed itself to carbon neutrality by 2050. The Swedish Gas Association supports this commitment, and we are convinced that all sustainable technologies will be needed if the EU is to have a chance of succeeding. This is especially true for the decarbonization of the transport sector – one of the biggest challenges of the EU Green Deal. Despite all the current efforts at the EU level, the GHG emissions of the EU’s transport sector have increased every year since 2014. Today’s regulation structure has clearly not been sufficient.
The release of fossil CO2 has a cumulative effect and must be prevented. Relying on electricity only presents major drawbacks, which are described well in the feedback from the European Biogas Association (EBA) to this EC roadmap.
As the EU’s Strategy on Sector Integration states ‘the deployment of biofuels and biogases has so far been hampered by regulatory uncertainty’. The same strategy promises ‘opportunities for further targeted support to accelerate the development of the market for biofuels and biogases’. However, these fuels cannot be deployed if the vehicle manufacturers are asked to focus unilaterally on certain types of passenger cars, i.e. electric ones. The European Commission shall understand such interlinkages between different pieces of legislation.
The revision of the CO2 emission standards for cars and vans represents the timely opportunity to introduce a new paradigm in the regulation structure. Today, this regulation not only misses the technology neutrality principle, but instead forces the switch towards “zero” and “low-emission” vehicles through the measurement of tailpipe emissions only. If fighting climate change is the objective, CO2 tailpipe emissions represent only a part of the reality, ignoring the critical contribution of sustainable biofuels and biomethane.
The revision should introduce into the regulation a level playing field, recognizing the contribution in emissions reduction achieved using biomethane and other advanced renewable fuels.
Biomethane represents one of the absolute lowest greenhouse gas intensive options applicable to decarbonization of road transport, similar to the use of renewable electricity and e-fuels. This is concluded in the recently published Well-To-Wheels report by the Joint Research Centre of the EC (https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-reports/jec-well-wheels-report-v5).
It’s important to consider the comprehensive, transparent and objective work of the JRC study when revising the CO2 emission standards.
Biomethane turns a waste problem into a resource. Scientific findings also show that biomethane contributes, directly or indirectly, to every one of the 17 UN Sustainable Development Goals (http://www.biogasost.se/Portals/0/Publikationer/Rapporter/2016_Cirkular_Ekonomi_vetenskaplig_rapport.pdf). This makes biomethane unique compared to other alternatives in the areas of waste treatment and transport. Biomethane is the link and enabler in and between central policy areas such as agriculture, waste management, transport, industry and energy production. That is not only smart, but super-smart sector integration. Furthermore, being based on proven technologies, biomethane is readily available, scalable, affordable and contributes to maintain a strong automotive industry in the EU.
In the Nordic countries, politicians have identified biomethane as a unique and valuable resource to society. Please learn more about biogas for mobility in the Nordics: https://www.energigas.se/library/2976/nordic-joint-paper-on-biomethane-in-transport.pdf.
Biomethane has a great potential in the rest of Europe as well (as described in the feedback from the EBA). Hence, the EU should follow the Nordic example to accelerate the decarbonization of transport and achieve Sustainability Development Goals in a cost-effective way. However, the tailpipe approach in the EU regulation hampers any efforts to do so.
Read full responseResponse to Updating the EU Emissions Trading System
26 Nov 2020
The EU Emissions Trading Scheme, EU ETS, aims to reduce fossil emissions in the most cost-effective way. But this is not possible for industries and energy production plants that use fossil gas as a fuel and gradually choose to switch to renewable gases such as biogas or bio-LPG. The reason is that there are shortcomings in the current EU ETS regulations. That shortcomings must be rectified before the policy instrument are broadened and additional sectors are included, such as the maritime sector, buildings or the transport sector. One such shortcoming is that renewable gases co-distributed with fossil gases are counted as fossil within the EU ETS. For example biomethane injected in gas grids and co-distributed with natural gas, should be accounted for as renewable and thereby eligible for emission factor 0 by ETS operators. That is not the case today. This is a barrier for large biomethane expansion within the EU ETS and leads to that industry and heat and power plants have no possibility to reduce their emission allowance costs by increasing their use of biogas or bio-LPG. This is a problem today, and it will be an even bigger problem if the EU ETS is broadened and more sectors are included, if these problems are not addressed. To clarify why this is even more important if the transport sector is included in the EU ETS, we can proudly share the information that vehicles in Sweden are refuelled with renewable and sustainable biomethane, resulting in a world-leading biomethane share of 95 percent. Swedish politicians have contributed to this success story by ensuring long-term tax exemption on biomethane. It is important that new steering instruments, such as an extension of the EU ETS to include new sectors, helps and not risk to hinder the conversion to renewable fuels which has already come a long way in Sweden and many other member states.
The Swedish Gas Association states that this problem should be solved by introducing what we call a green gas concept, which means that biogas and bio-LPG users connected to the gas grid or in a local grid can buy and claim any share of biomethane or bio-LPG even though it is a physical mix of fossil gas and renewable gas. The biogas and bio-LPG content shall be decided by the purchasing contracts between the user and the supplier, and the supplier must assure that the same amount has been injected to the grid. Transmission capacity from the injection point must thus be booked. Off course, the green gas concept should be applicable for both imported and domestic biomethane and bio-LPG. However, in light of the phase 4 (2021-2030) revision of the EU ETS, the regulation on monitoring and reporting (MRR) and the regulation on verification and accreditation (AVR) are currently under review. We hope that the ongoing revision of the MRR will make it possible to decide for biogas and bio-LPG content by the purchasing contracts between the user and the supplier.
The Swedish Gas Association think that it is positive that the EU-Commission wants to provide the maritime sector with tools to switch to renewable fuels. As we wrote in the beginning of this paper, all sectors must be given the opportunity to contribute to the climate goals. The maritime sector needs clear instruments that provide the impetus for the transition to renewable fuels. But in this context, it is extremely important to consider that shipping is a sector exposed to international competition. If the ETS only includes intra-EU voyages, advantageous competitiveness for non-EU parties must be addressed to ensure a levelled playing field for shipping companies providing transports services within, to and from the EU. Finally, it is also important to not create an EU ETS system where ships, instead of switching to renewable fuels, bunker on international waters. Such a consequence would be neither favourable to the climate nor to the EU economy.
Read full responseResponse to Sustainable and Smart Mobility Strategy
29 Jul 2020
Using biomethane for transport improves air quality and can lead to carbon neutrality. In Sweden, the share of biomethane in gas used for transport is 94%. Renewable methane is already produced in increasing volumes in most European countries; the technology is mature and biomethane profits also from the existing natural gas infrastructure in Europe. This means that we do not have to wait for the future, biomethane can play a crucial role in the transport sector today!
The inclusion of CNG and LNG in the definition of alternative fuels should be maintained as relevant part of the EU’s decarbonisation goal. The progressive incorporation of renewable gases is able to make CO2- emissions dropping significantly for both current and future fleets. The continuous inclusion of these fuels would enable a progressive transition of the transportation system, ensuring affordability and at the same time good environmental performance. The CNG and LNG infrastructures serves today both private and professional users. Biomethane represents an immediate solution, especially for those transportation modalities which have no electrification alternatives to be decarbonised. It offers the opportunity to act on the current fleet, taking advantage of an infrastructure already in place.
Apart from its main use in road transport, natural gas has started becoming an ever more interesting solution in maritime application where heavy-fuel oils are replaced by clean fuels such as LNG. The infrastructure and engines for CNG and LNG can also be used for biomethane as soon as it is getting available in larger volumes.
The legislation at EU level is necessary to accelerate the switch to alternative fuels EU-wide. However, the Members States’ implementation at national level, including planning and coordination on biomethane’s infrastructure, has not been sufficient. The measures introduced are not concrete enough to be effective and the national plans should not focus on individual fuels; all alternative fuels are needed to decarbonise the transport sector. We expect the binding mandate for advanced biofuels in the new Renewable Energy Directive to create demand for gas-driven vehicles and it is important that it is supported by sufficient filling infrastructure for both CNG and LNG. To facilitate a homogeneous market throughout Europe, consistency must be ensured across the different legislations and EU projects putting in place such measures at the national levels to guarantee interoperability among European countries.
Besides being one of the most sustainable fuels according to the sustainability criteria set by the RED II, biomethane heavily contributes to the CO2 reduction when used as fuel in transport. This must be acknowledged and accounted also in the legislation ruling on CO2 emissions in the mobility sector, i.e. the directive of Alternative Fuels Infrastructure (DAFI), the CO2 standards for Cars and Vans, targets for zero- and low-emission vehicles in public procurement and the EU Heavy-Duty vehicle CO2 regulation.
When looking at the total emissions on a well-to-wheel basis, biomethane has a huge, unrecognized, role to play. In comparison with petrol and diesel, natural gas generates already a GHG emission reduction of up to 23%. The mitigation effect becomes close to zero, or even negative, when considering biomethane pathways. At the moment these savings cannot be accounted anywhere since a tank-to-wheel (tail-pipe) approach applied, ignoring and penalizing an industry which is currently boosting the European bioenergy sector.
The tailpipe approach does not acknowledge the climate benefits of renewable fuels. Only a Well-to-Wheel approach can guarantee a fair and complete assessment of the decarbonisation effect among different solutions, translating the need to ensure technology neutrality.
Read full responseResponse to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)
25 Jun 2020
Swedish Gas Association (Energigas Sverige) is the member association for the energy gases industry in Sweden, appreciate the opportunity to express our position on the abovementioned consultation. Our members cover technology providers, producers, suppliers, distributors, gas grid operators, gas users and other actors in the gas sector. We work for an increased market and better conditions for gaseous and liquid energy gases including natural gas, biogas/biomethane as well as LPG and bio-LPG and hydrogen. Our vision is a 100 percent renewable gas sector in Sweden by 2045.
Our comments are mainly focused on the revised Article 39 regarding biomethane injected in gas grids.
Swedish Gas Association strongly support that the biomass fraction for purchased biomethane co-distributed with natural gas in a gas grid should be based on purchase agreements along with proof of compliance with the sustainability criteria, as proposed in Article 39 (4). It is important that this approach is the only option for the interconnected European gas grid and is implemented by all member states. Option 2 in paragraph 5 could be an option for isolated smaller grids. We have some concerns and proposals:
• the implementation of Article 39 should not wait until 2022
• control systems, audits and sustainability information provided under national sustainability criteria schemes or by Voluntary Certification Systems should be recognised by ETS. Purchase records, proof of sustainability (and when relevant cancellation of certificates/guarantees of origin) should be enough to comply with the requirements in points a) to c).
• the requirement that support systems for biomethane should take the market price for use in ETS into account is rather an issue for the State Aid Rules and shall not be a requirement put on the ETS operators.
• the mass balance approach, or allocation by actual purchase agreements, proposed for biofuels used in aircrafts in Article 54 instead of using analyses should be allowed for all gaseous biomass fuels, including bio-propane.
This is just a summery. Please read our full answer in the attached file.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
4 May 2020
Using biomethane for transport improves air quality and can lead to carbon neutrality. In Sweden, the share of biomethane in gas used for transport is 94%. Renewable methane is already produced in increasing volumes in most European countries; the technology is mature and biomethane profits also from the existing natural gas infrastructure in Europe. This means that we do not have to wait for the future, biomethane can play a crucial role in the transport sector today!
The inclusion of CNG and LNG in the definition of alternative fuels should be maintained as relevant part of the EU’s decarbonisation goal. The progressive incorporation of renewable gases is able to make CO2- emissions dropping significantly for both current and future fleets. The continuous inclusion of these fuels would enable a progressive transition of the transportation system, ensuring affordability and at the same time good environmental performance. The CNG and LNG infrastructures serves today both private and professional users. Biomethane represents an immediate solution, especially for those transportation modalities which have no electrification alternatives to be decarbonised. It offers the opportunity to act on the current fleet, taking advantage of an infrastructure already in place.
Apart from its main use in road transport, natural gas has started becoming an ever more interesting solution in maritime application where heavy-fuel oils are replaced by clean fuels such as LNG. The infrastructure and engines for CNG and LNG can also be used for biomethane as soon as it is getting available in larger volumes.
The legislation at EU level is necessary to accelerate the switch to alternative fuels EU-wide. However, the Members States’ implementation at national level, including planning and coordination on biomethane’s infrastructure, has not been sufficient. The measures introduced are not concrete enough to be effective and the national plans should not focus on individual fuels; all alternative fuels are needed to decarbonise the transport sector. Binding targets, set at the EU level, for filling stations per each alternative fuel would be necessary. We expect the binding mandate for advanced biofuels in the new Renewable Energy Directive to create demand for gas-driven vehicles and it is important that it is supported by sufficient filling infrastructure for both CNG and LNG. To facilitate a homogeneous market throughout Europe, consistency must be ensured across the different legislations and EU projects putting in place such measures at the national levels to guarantee interoperability among European countries.
Besides being one of the most sustainable fuels according to the sustainability criteria set by the RED II, biomethane heavily contributes to the CO2 reduction when used as fuel in transport. This must be acknowledged and accounted also in the legislation ruling on CO2 emissions in the mobility sector, i.e. the directive of Alternative Fuels Infrastructure (DAFI), the CO2 standards for Cars and Vans, targets for zero- and low-emission vehicles in public procurement and the EU Heavy-Duty vehicle CO2 regulation.
When looking at the total emissions on a well-to-wheel basis, biomethane has a huge, unrecognized, role to play. In comparison with petrol and diesel, natural gas generates already a GHG emission reduction of up to 23%. The mitigation effect becomes close to zero, or even negative, when considering biomethane pathways. At the moment these savings cannot be accounted anywhere since a tank-to-wheel (tail-pipe) approach applied, ignoring and penalizing an industry which is currently boosting the European bioenergy sector.
The tailpipe approach does not acknowledge the climate benefits of renewable fuels. Only a Well-to-Wheel approach can guarantee a fair and complete assessment of the decarbonisation effect among different solutions, translating the need to ensure technology neutrality.
Read full responseResponse to Revision of the Energy Tax Directive
1 Apr 2020
The Inception Impact Assessment points out that the ambitious EU Climate ambition requires effective carbon pricing and the removal of fossil fuel subsidies. It also specifies that well-designed taxes play a direct role by sending the right price signals and providing the right incentives for sustainable practices of producers, users and consumers. The Swedish Gas Association agrees that effective carbon pricing is required. Regarding fossil subsidies, the Swedish Gas Association wants to emphasize that natural gas is absolutely necessary to create and maintain a competitive market for biogas. For that reason, a favourable taxation of natural gas is decisive for the development of the biogas market. The same situation prevails for the market for bio-LPG and LPG. Without a market for fossil gases, we will not have a future market for biobased gases.
Environmental taxes are steering taxes, with the purpose to change the behaviour and the choices persons and companies do every day. Therefore, the tax design often needs to include state aid elements to ensure overall best environmental results. Biogas and high blended biofuels are generally more expensive to produce than petrol and diesel. We need an ETD that allows a lower taxation of biofuels than of fossil fuels, without including state aid. Therefore, low minimum tax levels for biofuels should be introduced in the ETD, instead of using taxation in the same level as equivalent fossil fuel as is done today.
The ETD should also be aligned with the zero-pollution strategy, which is to be developed under the European Green Deal. Therefore, the calculation of minimum rates should, beside energy and fossil carbon content, also reflect an energy product's impact on air quality.
The Swedish Gas Association also want to take this opportunity to write a few words about one special biofuel, namely biogas. There are many reasons to support the production and use of biogas. Biogas is a climate-smart biofuel, but it also fulfils many other social benefits. Biogas is a unique asset for society - and more important than ever. In practice, biogas is a circular economy, where waste produced by the community is transformed into renewable energy and biofertilizer. At a summit held on 25 September 2015, the UN decided on Agenda 2030 with its 17 global goals, balancing the three dimensions of sustainable development: economic, social and environmental. Biogas contributes, directly or indirectly to all 17 goals.
In order to optimise the use of biogas as a resource, long-term instruments are required in order to promote both increased demand and increased production of biogas and biofertilizer. The list of social benefits from biogas can be made long, but biogas is also a fuel with special needs. It is of the utmost importance that biogas can be tax-exempt without risking overcompensation, as taxation on fossil fuels rises on the way to the climate goals. This should be done by introducing a zero (or at least very low) minimum tax level for biogas. It is also important to remember that if natural gas loses its competitiveness, also the biogas market will likely decrease substantially or even disappear. One example is the situation for biogas as motor fuel. An increased tax on natural gas as motor fuel would most likely mean the end of the European gas car market.
ETD also need to contribute technology development. New fuels are gradually being developed that can eventually replace fossil fuels. An example is bio-LPG, which for example can be produced from residues in the same process as HVO (biodiesel). In order to encourage this type of development, bio-LPG, just as biogas, needs a zero (or at least very low) minimum tax level. Bio-LPG cannot bear the costs of infrastructure expansion etc. For that reason, it is important to remember that also the competitiveness for LPG is needed to expand the possible market for bio-LPG. Without a market for LPG, we will not have a future market for bio-LPG.
Read full responseResponse to Implementing act on a common methodology for alternative fuels unit price comparison
31 Mar 2018
We welcome the initiative to create regulation on fuel price comparison between the conventional automotive fuels and the alternative fuels growing in importance, in order to facilitate for automotive consumers in Europe to make more well informed choices.
- We are in favour of using a fuel price comparison system based on energy content. Using 10 kWh as base is probably the best choice, given that most automotive fuels are retailed in units with an energy content of that order of magnitude. The choice of the kWh unit makes comparison with electric vehicles possible. Information provided online is a suitable media to increase knowledge about the differences in fuel efficiency among different fuels, comparing the differences of well known conventional fuels, such as diesel and petrol, with the alternative powertrains of natural gas/biomethane, hydrogen (fuel cell) and electricity.
- It is not feasible to create a fuel price comparison system based on fuel consumption per 100 km which does not mislead the consumer. Estimated average values can only be valid for a specific vehicle type, and inherently flawed by the necessary compromises when choosing slightly differing models for each type of fuel to be compared. In addition, individual driving patterns also make such comparisons less meaningful. Fuel efficiency variations within the vehicle park of each alternative fuel, or use of the suggested outdated fuel efficiency data of JRC for different power trains would lead to market actors questioning the credibility of the fuel price comparison system, and probably eventually also among consumers.
- The current gaps in knowledge on how consumers would assimilate and find use of different fuel price comparison systems, together with the considerable costs any such refuelling station based implementation would entail for all market actors, we think it would be wise to refrain from implementing such regulations on refuelling stations, at least not in the first stage of regulations. In the future, after proper investigation of the resulting consumer information uptake, it is possible to add features to the system with less risk of mistakes.
- It is not reasonable to ask of refuelling station owners and fuel distributors to make price comparisons for by them not marketed automotive fuels. Such comparisons are more suited on homepages and platforms for authorities, and possibly also as a requirement for vehicle vendors.
- Given the situation that electric vehicle charging in principal never is offered in conjunction with the refuelling stations of other fuels, it would only be confusing for customers to add electricity to any compulsory filling station based price comparisons. Fuel efficiency comparisons of different vehicle types and fuels are more efficiently communicated through other channels, such as dedicated platforms of authorities and vehicle vendors.
Read full response