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VNG AG

VNG ist ein europaweit aktiver Unternehmensverbund mit über 20 Gesellschaften und ca.1.700 Mitarbeiterinnen und Mitarbeitern.

Lobbying Activity

Meeting with Maroš Šefčovič (Commissioner) and

11 Nov 2025 · EU-US-China Relations in the Gas and Energy Sector

Meeting with Christian Ehler (Member of the European Parliament)

29 Oct 2025 · Methanemissionsverordnung

Meeting with Christian Ehler (Member of the European Parliament)

23 Sept 2025 · Energy policy

Meeting with Jens Geier (Member of the European Parliament)

23 Sept 2025 · Exchange on Delegated Act on Low Carbon Hydrogen

Meeting with Jens Geier (Member of the European Parliament)

14 Jul 2025 · Exchange on the Methane Regulation

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

The following suggestions aim to further develop and improve the system to ensure the effective reduction of emissions in the EU: - The effectiveness of the current instruments could be improved: Through the invalidation mechanism of the MSR, the carbon budget has effectively been reduced below the level implicitly agreed upon in the ETS Directive. This has destroyed liquidity that should have remained available to the system for meeting future compliance needs. Looking beyond 2030, a shortage of allowances in ETS1 is more likely than a surplus. While the MSR has addressed the problem of oversupply, it has not proven effective in responding to scarcity, which will become an increasingly important issue in the future. Administrative efficiency could be improved and regulatory costs reduced by: - Ensuring coherent and equivalent certification and verification procedures across ETS and RED, allowing the same accredited body to certify and verify installations under both schemes to avoid duplication and reduce costs. - Aligning implementation timelines of related EU legislation (e.g. ETS and RED II/III) to prevent administrative challenges. - Simplifying reporting requirements for sectors covered by the CBAM, developing standardised digital tools for monitoring, reporting, and verification (MRV), and enhancing international cooperation to improve emissions data transparency. - Introducing default values for key waste categories with respect to calorific value, CO2 emissions, and biogenic share (e.g. for mixed municipal waste, sewage sludge from public wastewater treatment, and waste wood). - The recognition of biomass-based energy sources as zero emission rated is not yet standard practice across the EU, especially in the case of biogas and biomethane. More clarity, harmonisation, and uniform application of requirements and supporting documentation are needed to ensure the widespread recognition of the zero-emission factor. - The administrative burdens related to ETS participation are substantial: biogas and biomethane producers must often undergo complex double verification under both ETS rules and RED frameworks, and they face unclear criteria for how to prove actual GHG emissions reductions.
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Meeting with Christian Ehler (Member of the European Parliament)

13 May 2025 · EU Energiepolitik

Meeting with Jens Geier (Member of the European Parliament, Shadow rapporteur)

7 Apr 2025 · Exchange on the Gas Storage Extension Regulation

Meeting with Christian Ehler (Member of the European Parliament)

27 Feb 2025 · EU Gasmärkte

Meeting with Christian Ehler (Member of the European Parliament)

17 Feb 2025 · Wasserstoff

Meeting with Christian Ehler (Member of the European Parliament)

19 Nov 2024 · EU Energiepolitik und Wasserstoff

Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

VNG is a group of over 20 companies active in the European energy industry. The Group is a gas importer and wholesaler, the second-largest transmission system operator and the third-largest gas storage operator in Germany, ensuring a secure supply of gas. VNG's aim is to drive forward the import, production, transport, storage and distribution of renewable and decarbonized gases and thus actively shape the transformation towards a climate-neutral energy system together with existing natural gas customers and future hydrogen users. VNG therefore believes that a pragmatic approach to the delegated act on the methodology for determining greenhouse gas savings from low-carbon fuels is absolutely necessary in order to enable companies such as VNG to develop viable business models that translate the energy and climate targets into practical action by creating the appropriate political framework conditions and thus also regulatory legal certainty. The European hydrogen strategy of 2020 and the RePowerEU plan of 2022 provide for 10 million tons of renewable hydrogen to be produced within the EU by 2030 and up to a further 10 million tons to be imported. The total capacity of installed electrolysis capacity in the EU should be at least 100 GW by 2030. In view of the current expansion rates of renewable energies in Europe, the current RFNBO volumes will not be able to cover the demand for hydrogen in the foreseeable future. Consequently, there is a risk of a stagnating hydrogen ramp-up and an obstacle to transformation processes, particularly in energy-intensive industry, in heavy and long-distance transportation and in shaping the heating transition. In order to ensure the necessary supply at economic prices and guarantee security of supply, a broad use of low-carbon hydrogen is required, especially in the ramp-up phase. We therefore need imports of renewable and low-carbon hydrogen and its derivatives and should also use domestic production of low-carbon hydrogen to meet the needs of industry and other consumers. However, the still outstanding regulatory measures that are so important for the further hydrogen ramp-up, such as the delegated act, must be pragmatically developed and then quickly adopted also because the energy industry within the EU is in international competition with other regions of the world in terms of imports. Please find our specific recommendations for the delegated act in our attached VNG position paper.
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Meeting with Christian Ehler (Member of the European Parliament)

2 Sept 2024 · Wasserstoffkernnetz Deutschland

Meeting with Thomas Geisel (Member of the European Parliament)

20 Aug 2024 · Exchange on Energy Issues

Meeting with Christian Ehler (Member of the European Parliament)

20 Mar 2024 · NZIA

Meeting with Christian Ehler (Member of the European Parliament) and Centre for European Policy Studies

14 Nov 2023 · EU-Energiepolitik

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

VNG is a group of enterprises active throughout Europe with over 20 companies and more than 1,500 employees. Headquartered in Leipzig, the Group is Germany's third-largest gas importer and storage operator and operates 7,700 km of long-distance pipeline system via ONTRAS Gastransport GmbH to ensure a secure supply of gas in Germany and its neighboring countries. VNG supplies gas to around 400 municipal utilities and industrial customers, covering around 20 percent of Germany's gas demand. In addition, VNG is pursuing an ambitious path for its commitment to renewable and decarbonized gases with its "VNG 2030+" strategy. VNG is already one of the leading biogas producers in Germany and is actively involved in many projects to build a CO2-neutral hydrogen economy. Based on its core competencies in gas and critical infrastructure, VNG is thus working along the entire gas value chain towards a sustainable, supply-secure and, in perspective, climate-neutral energy system of the future. In addition to the avoidance and substitution of fossil fuels, the goal of climate neutrality can also be actively supported by the safe capture, storage and use of carbon dioxide. This is necessary both for early decarbonization of industry and for dealing with unavoidable CO2 emissions. Carbon Capture and Storage (CCS) is already available today. Projects are being developed nationally and internationally with the aim of closing the carbon cycle. In addition, CCS technology also enables so-called negative emissions through the safe storage of biogenic carbon dioxide (BECCS - Bioenergy with Carbon Capture and Storage). European industry is dependent on carbon in industrial production processes, which in the long term must also be procured through Carbon Capture and Utilization (CCU), as the substitution of fossil energy sources progresses. Regulation of these technologies at national, European, and international level is currently in an early stage. However, to ensure a rapid ramp-up, potential investors need timely clarity on the scope and design of CO2 infrastructure regulation. VNG therefore welcomes the fact that the European Commission is currently holding a public consultation on industrial carbon management. With our attached VNG statement, we would like to provide suggestions for a practical and sensible design of the future regulation of carbon management.
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Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

6 Jul 2023 · Exchange on the Gas Market Directive

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur)

15 May 2023 · Horizon Europe, NZIA

Meeting with Matthias Ecke (Member of the European Parliament)

8 May 2023 · Meinungsaustausch zur Industrie- und Energiepolitik

Meeting with Mohammed Chahim (Member of the European Parliament)

24 Mar 2023 · Air Quality

Meeting with Christian Ehler (Member of the European Parliament)

13 Jan 2023 · Allgemeiner Austausch

Response to Revision of EU rules on Gas

12 Apr 2022

In view of the current geopolitical developments it is now necessary - with a holistic focus on the economy, politics and society - to succeed not only in overcoming the acute crisis in shaping the future, but also in bringing together security of supply and climate protection to a much greater extent, while not losing sight of the economic viability and affordability of energy supply for industry and consumers. A more rapid transformation towards green gases and hydrogen as well as a diversification of natural gas supplies is therefore indispensable. In this context, it is particularly important to quickly create stable and reliable rules for a market ramp-up of renewable and decarbonised gases. VNG has identified the following key points of the gas package as obstacles to a rapid switch to green gases: 1. Strict unbundling regulations from 2030 onwards may become a threat to the financing of the H2 infrastructure and create redundant structures a) Vertical unbundling (Directive Art. 62) VNG sees no reason to tighten these rules for the development of a hydrogen infrastructure in the way proposed. The planned ownership unbundling makes it more difficult for existing gas network operators and integrated energy supply companies to enter the hydrogen economy or to build up the necessary hydrogen infrastructure. The limitation of the ITO model for hydrogen network operators would have the consequence that numerous European transmission system operators would be de facto excluded from the hydrogen transport business. This would thus jeopardise the very existence of a European backbone network for hydrogen. VNG therefore pleads for the deletion of the time limit for the ITO model in Article 62 of the Gas Directive. b) Horizontal unbundling (Directive Art. 63) In VNG's view, unbundling under company law between hydrogen network operators on the one hand and network operators for natural gas/biomethane or electricity on the other is not advisable. On the one hand, such an approach leads to the establishment of inefficient and cost-intensive duplicate structures and prevents the exploitation of synergies between the operation of the gas network and the hydrogen network. In addition, a separation under company law does not create any added value in terms of (cost) transparency. For the reasons mentioned above, VNG advocates the abolition of the unbundling provisions under company law (deletion of Art. 63 of the Gas Directive). 2. Delegated act to define only by the end of 2024 is too late (Directive Art. 8, 5) It is also critical that the EU Commission reserves the right to define the calculation methodology for the above-mentioned renewable and decarbonised gases by means of a delegated act only by 31 December 2024. From VNG's point of view, this calculation methodology is a fundamental part of the definition. This brings uncertainty in the medium term. Major investment decisions for production plants are already pending, which of course also depend on the recognition of the gases produced as low-carbon. In the negative case, these decisions could be postponed by 3 years. For this reason, VNG pleads for a faster definition of the calculation methodology, in the best case as part of the directive. 3. Certification of renewable and decarbonised fuels should be practicable (Directive Art. 8) The introduction of a uniform Europe-wide mass balancing system in accordance with RED II is in principle a positive signal for trade in renewable and decarbonised gases. However, the proposed use of a Union database appears to VNG to be excessively complex and entails too much administrative effort. A uniform Europe-wide database would make trading much easier, as no transfers between different mass balance systems would be necessary and uniform criteria would be used as a basis.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur)

10 Feb 2022 · RED III