Joint industry recommendations for simplification of the importer requirements of the EU Methane Regulation

As the MRV equivalency requirements scheduled to apply from 1st January 2027 are, for the reasons outlined below, not feasible to achieve in practice in the given timeline, we call for the stop-the-clock and consideration of the targeted amendments proposed in this document.

We, the undersigned representatives, fully support the objective of reducing methane emissions by the EU Methane Emissions Regulation (EUMR) and EU’s ambition to reduce greenhouse gas emissions and advance global climate leadership. Our sector is actively advancing efforts to reduce methane emissions through innovation (e.g., investing in advanced monitoring technologies), voluntary action (e.g., OGMP 2.0), and engaging in collaborative projects with international partners to deliver methane reductions (e.g., OGDC).

Our goal is to ensure that the EUMR’s provisions are effective, achievable and practical - achieving real environmental impact while safeguarding Europe’s energy security, competitiveness, and industrial resilience.

The importer requirements of EUMR introduce a new layer of compliance risks and contractual complexities for natural gas, LNG and crude oil importers, which will affect crude and natural gas markets whilst putting a significant burden and compliance risk on EU importers, with uncertain extraterritorial implications, which is expected to reduce supply options for the EU, reduce operational flexibility and increase costs for compliant molecules.

These challenges are exacerbated as the EU is looking for more diverse supply, notably following the phase-out of natural gas supply from Russia.

The most pressing issues are linked to equivalency requirements that start in 2027:

• Many crude oil and natural gas producers in third countries will simply not be able to meet the high requirements for equivalency in time.
• This is partly due to the lack of clarity around, and availability of, recognized verification protocols, as well as the limited number of accredited verifiers with expertise on methane measurement, and the time typically required to complete such independent verification for a particular asset/operator.
• In addition, importers often cannot identify the producer as supply chains are usually complex with the product being traded many times including at virtual trading hubs or from portfolios.
• The use of certificates as requested by industry is not yet clarified and not fully enabled, despite the Commission’s ongoing work on recommendations related to certain high-level criteria for certification. However, implementation of the necessary schemes and suggested controls (e.g., audits) will take time and likely further delay the availability of certification across all relevant exporting countries, for both crude oil and natural gas.
• The uncertainty linked to penalty schemes and - given the above issues - the significant compliance risk for importers and suppliers is already deterring deliveries into the EU for the period beyond 2027 and can lead to serious security of supply issues and price increases. This applies in particular toc rude oil imports because refining operations are designed and optimized around certain crude oil grades/blends and changing supplies will come with a loss of processing capacity, efficiency and flexibility.
• Article 28 is designed to ensure robust methane emissions measurement by producers in preparation for the methane intensity thresholds set by Article29.Therefore, targeted amendments to the relevant provisions are both urgently needed and justified to ensure that consecutive steps are coherent, proportionate, and practically implementable.
• As fixing the issues via “simple and robust implementation” is impossible because additional rules e.g. on Member State (MS) level cannot simply deviate from EUMR provisions and would lead to many different country-level rules, a relief with legal certainty for all actors to avoid unnecessarily jeopardizing security of supply or competitiveness, can only be achieved via targeted simplification coupled with a stop-the-clock mechanism, to allow comprehensive stakeholder consultations addressing fundamental issues of the EUMR, and allow market participants to operationalize all necessary elements for compliance in a structured, effective, and legally certain manner (e.g., approaches to ‘traceability’, setting penalties).

Without targeted adjustments/simplification following a stop-the-clock process, a recent study found that by 2027 up to 43% of natural gas volumes and up to 87% of crude oil volumes could be non-compliant. While the EUMR does not formally prohibit the import of non-compliant natural gas and crude oil, the associated legal, financial, and reputational liability risks for EU importers are substantial – particularly in a context where securing sufficient compliant volumes to meet the EU demand as of January 2027 will be extremely challenging.

These risks are, therefore, likely to deter imports, reduce production capacity in European refineries and jeopardize the security of affordable energy supply. As the exact impact is hard to determine, the same study used another scenario that considers modifications to EUMR leading to a wider amount of compliant products, which still showed a significant impact on prices, shortening of supply, industry competitiveness, and on the overall EU security of oil and natural gas supply.

Contrary to concerns that amending the EUMR would undermine regulatory certainty, a limited and well-defined adjustment of the primary legislation, during a period when implementation deadlines are frozen and enforcement of penalties is paused, is precisely what is required to address structural issues and to deliver clarity, consistency, and legal certainty for operators, investors, and MSs/Competent Authorities (CAs).

Whilst we welcome Commission’s guidance to MSs/CAs on ‘flexible implementation’, it will not be sufficient or able to fix the issues from overly prescriptive requirements and unrealistic timelines in the EUMR and comes with the risk of diverging interpretation and application across MSs that can distort the Union markets for crude and gas/LNG.

The proposals set out in the Annex, which have been developed by the undersigned associations, are non-exhaustive and seek to ensure that the importer requirements under Chapter 5 of the EUMR are implemented in a manner that is effective, proportionate, and operationally feasible, without undermining the objectives of the Regulation.

We highlight some of the key proposals:

• Set a conditional, time-bound deferral of Articles 28 & 29 until essential secondary legislation, MRV standards, methodologies, and verification systems arein place, to provide all stakeholders (incl. verifiers) with sufficient time to develop and set up compliance options.
• Revise producer- and country-level MRV equivalency criteria to make compliance achievable whilst using credible, internationally recognized approaches(including OGMP 2.0 Levels 4–5 pathways), while preserving the EUMR’s ambition to drive high-quality emissions data and abatement.
• Allow third-party verification at a “limited assurance” level, reflecting current verifier capabilities and ensuring scalability across global supply chains.
• Allow the use of voluntary certification schemes for cases where importers cannot identify the producer of the imported quantities.
• Adjust penalty criteria to reflect the physical and commercial realities of crude oil and natural gas markets (e.g. molecule commingling, crude grade constraints), and the limitations of tracing volumes to producers.
• Introduce grandfathering provisions and clarify the treatment of secondary contracts to preserve legal certainty, market liquidity, and security of supply.
• Anchor the importer definition firmly in the Union Customs Code to ensure legal certainty, consistent enforcement across MSs, and clarity on responsibilities for EU- and non-EU-established entities.

Finally, and regardless of the recommended adjustments, it would be advisable for the European Commission to conduct a thorough impact assessment of the importer requirements, focusing on key criteria such as workability, environmental effectiveness, security of supply and competitiveness.

Download the document to see further details