IOGP written input to the public consultation on the revision of the Energy Taxation Directive (ETD)

This document provides IOGP’s written input to the Commission’s consultation on the revision of the
Energy Taxation Directive (ETD).

The ETD should be an instrument that incentivises the use of all low-carbon/low-emission energy technologies and fuels. IOGP encourages the Commission to acknowledge the role of natural, low-carbon and renewable gases (including e-fuels, green and low-carbon hydrogen) in the revision of the ETD.


Key Points


  • IOGP considers it is essential that tax treatment of natural gas and low-carbon gases in heating,
    power generation and transport reflect, inter alia, their contributions to reducing CO2 emissions
  • Any tax incentive for hydrogen used as an energy carrier should cover both renewable and low-carbon hydrogen to ensure creating a true hydrogen ecosystem in Europe
  • To avoid overlapping legislation and ensure coherence we discourage the Commission from incorporating provisions aimed at tackling air pollution into the ETD
  • IOGP believes that sectors within the scope of ETS should not be targeted by any additional taxation for environmental or climate reasons




  • Introduction
  • While reviewing the Energy Taxation Directive, the following aspects should be considered:
    • Incentivise the use of all low-carbon energy technologies and fuels
    • Avoid overlapping legislation or double taxation
    • Impact assessment: include the cost-benefit analysis for households and the industry
  • Final remarks

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