ERGaR’s certification proposals seeks quarterly accounting and fewer trading barriers in EU certification overhaul

ERGaR and seven partner associations want the EU’s revised certification rules to preserve flexible renewable-gas trading while strengthening traceability. Their intervention combines requests to retain existing mass-balance arrangements, adjust proposed reporting and auditing requirements, and resolve uncertainties over imports and certificate cancellation. The most contested issue is bio-LNG: industry participants disagree over how physical and “virtual” liquefaction should compete.[1]

The central concept is mass balance: renewable attributes can be allocated to equivalent withdrawals from a recognised interconnected system, subject to accounting controls, without tracing individual molecules. Two instruments carry the claim, and they do different jobs.

PoS
Proof of sustainability

Documents sustainability and greenhouse-gas performance.

GO
Guarantee of origin

Serves a separate origin-disclosure function.

Their coordination matters because the same renewable production must not support competing claims.[2]
Mass-balance period
Current baseline

Regulation 2022/996, Article 19(2)(l), provides three months for ordinary operators, with twelve months for specified agricultural and forestry operators.

Change sought

Retain three months instead of the proposed one-month period.

Reporting deadlines
Current baseline

RED Article 31a(2) requires timely, accurate reporting. Commission guidance separately describes monthly injection volumes verified by transmission or distribution system operators.

Change sought

Extend injection validation from five to approximately fifteen days; reconsider fifteen-day transaction registration and ten-day counterparty acceptance.

Network boundaries and stocks
Current baseline

Articles 2(18), 2(21) and 19 recognise interconnected infrastructure and product groups. Carry-forward provisions link sustainability balances to stocks.

Change sought

Preserve network-wide equivalence and product-group similarity; exclude transmission/distribution infrastructure from stock-capacity proof; recognise Ireland within the system.

Third-country access
Current baseline

RED Article 30(9) protects acceptance of recognised-scheme evidence within its recognised scope. Certification recognition and practical UDB access nevertheless address different requirements.

Change sought

Publish admission criteria, timelines and transitional arrangements; clarify responsible authorities; remove the customs-clearance gate and compulsory C14 testing for mass-balanced imports.

GO and national registries
Current baseline

RED Article 31a(4) already requires issued GOs to enter the UDB with the registered gas, cease separate outside trading and be cancelled after withdrawal.

Change sought

Link registries at plant level, harmonise energy units, and clarify export cancellations and national certificates derived from UDB data.

Reconciliation and reporting are separate controls

The commercial distinction is between how often operators reconcile their accounts and how quickly they report individual events. A three-month balancing period does not authorise quarterly-only database updates. Shortening reconciliation to one month would reduce the time available to match eligible supply and sales; faster reporting could improve oversight without necessarily requiring that shorter balancing period.

Current rule Commission proposal Associations’ request
Ordinary operators · current3
Ordinary operators · proposed1
Ordinary operators · requested (retain)3
Specified agricultural and forestry operators · current12
Injection validation · proposed5
Injection validation · requested≈15
Transaction registration · proposed15
Counterparty acceptance · proposed10
Associations ask for both proposed deadlines to be reconsidered.

Similarly, a deadline for final injection validation depends on when network operators can provide verified measurements. Requiring a producer to submit information before its network operator can validate it would create a compliance problem without improving the underlying measurement.

Further requests in the joint paper[12]

  1. 1Annual electricity-emissions updates
  2. 2More frequent feedstock-list reviews
  3. 3Recognition of qualifying renewable electricity procurement
  4. 4Clearer CAPEX-support disclosure
  5. 5Certified-only UDB trading
  6. 6Stage-by-stage GHG responsibilities
  7. 7Distinct cancellation terminology
  8. 8RFNBO rules accommodating hydrogen blending without mandatory deblending and treating renewable methane consistently

The Commission’s operational guidance distinguishes entry and exit transactions from intermediate transfers within the grid, for which it describes a dedicated PoS-transfer function.[3]

Eurogas’s separate August position goes further than a general request for clarification. It sees mandatory bundling as a constraint on liquidity and participation by businesses that are not gas shippers.[4]

At injection
Gas and PoS linked

Eurogas argues the PoS should be tied to the injected gas.

→ Within the common mass-balance system
PoS trades without gas title

Subsequent PoS trading should not require matching transfers of gas title.

The policy question is therefore concrete: what documentary connection to gas ownership must each certificate trader demonstrate?

The answer affects who can participate and how contracts are structured. It must also preserve a verifiable limit on claims against injected renewable volumes.

C14 testing and mass balancing evidence different things

The proposed C14 requirement raises a specific technical issue. Delegated Regulation (EU) 2023/1640 governs fuels produced by processing biomass and fossil feedstocks together. Its recital 1 expressly excludes the described case of a production unit using grid-withdrawn biomethane certified through mass balance. It therefore does not establish a general existing C14-testing obligation for all mass-balanced bio-LNG.[5]

Physical evidence
C14 testing

Examines the biogenic carbon physically present in a sample.

Documentary evidence
Mass balancing

Establishes the renewable attributes allocated through a documented supply chain.

Consequently, a physical sample cannot by itself validate—or disprove—the full accounting allocation. Any new testing requirement would need to explain how these two forms of evidence interact.

GO recognition and PoS acceptance follow separate articles

RED Article 19(11)
Third-country GOs

Recognition is restricted to specified agreement and direct-energy-trade conditions. The provision does not itself establish the conditions for accepting a PoS.

RED Article 30
Proof of Sustainability

Sustainability evidence follows a separate framework, including Commission-recognised certification schemes whose geographical coverage can extend outside the EU.

Consequently, the absence of a GO mutual-recognition agreement does not, under Article 19(11) alone, disqualify a separately certified PoS for imported biomethane. However, a valid PoS does not automatically guarantee access to the Union Database or eligibility for every compliance market: applicable mass-balance, traceability and double-counting requirements must still be satisfied.[6–8]

Exports and national certificates

For exports and national certificates, the practical requirement is a coordinated record of who uses the renewable claim and where it is retired. Creating another certificate from UDB data cannot safely create another independently usable claim to the same energy.

The coalition seeks equal treatment of three pathways. These distinctions underpin the industry’s requests for recognition of all pathways.[1]

PathwayProduction siteGas gridLNG terminal
On-site liquefaction

Biomethane is liquefied at a facility connected to its production site.

Physically liquefied
—
—
Grid liquefaction

Gas is withdrawn from the grid and physically liquefied, with renewable attributes established through certification.

Injected →
Withdrawn, physically liquefied
—
Liquefaction by equivalence

Attributes from renewable gas injected into the connected system are allocated to an equivalent LNG quantity at a terminal. The original renewable molecules need not be physically liquefied there.

Injected →
Attributes carried by mass balance →
Allocated to equivalent LNG
Physical gas flow Physical liquefaction Attribute allocation only

Existing EU policy does not simply exclude virtual liquefaction. In its 21 November 2025 parliamentary answer, the Commission envisaged UDB traceability for both physical and virtual liquefaction, accompanied by conversion factors and comprehensive emissions accounting.[9]

The disagreement concerns which liquefaction and transport emissions belong to the renewable LNG consignment. These are stakeholder positions on emissions attribution.

Eurogas and partners[10]

Oppose assigning the fossil LNG supply chain’s emissions to renewable attributes allocated within Europe.

e-NG Coalition[11]

Argues that accounting should reflect the additional energy actually used by each pathway.

Current Articles 10, 12 and 13 of Regulation 2022/996 already combine initial on-site audits, annual surveillance where certificates exceed one year, increased scrutiny for higher risks, and conditional group auditing. Existing rules do not guarantee that every operator receives only one audit annually.

ProposalValueEurogas position[4]
Standard audit interval 6months Opposes. Favours annual auditing with targeted checks.
Mandatory certification-body rotation 3years Opposes rotation after three years.
Individual on-site auditing threshold 1t / month Opposes a threshold that would expand individual on-site auditing. Favours workable group arrangements for dispersed waste suppliers.

These choices particularly affect small feedstock collection points: a fixed audit cost becomes more significant when spread across fewer tonnes. However, proportionality requires evidence about fraud risk and audit effectiveness; lower cost alone cannot establish the appropriate inspection frequency.

The eight signatories—ERGaR, EBA, Energy Traders Europe, e-NG Coalition, ENTSOG, Eurogas, Europex and GIE—represent a broad coalition supporting traceability while seeking trading flexibility. Europex specifically emphasises clear links between gas volumes, PoS and GOs without obstructing market liquidity.[13]

Their commercial priorities differ

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08 — Verdict

Clearer procedures have broad support; LNG accounting does not

The evidence therefore supports broad agreement on clearer certification procedures, alongside a substantive disagreement over LNG accounting and investment incentives. Claims that the recast would reduce supply or raise prices remain prospective industry assessments. Greater flexibility over balancing, liquefaction and retrospective cancellation requires equally clear safeguards.

The commercial value of certification depends on both its usability and the credibility of the claims it supports.