Access to EU markets for Ukrainian biomethane — Position paper by UABIO

In connection with the integration of the Ukrainian renewable gas market into the European energy market, ensuring that Ukrainian biomethane supplies comply with European Union law requirements has become particularly relevant.

We would like to share a document prepared with the participation of UABIO members. It highlights the issue of Ukrainian biomethane access to EU markets.

We believe that EU Member States should not treat compliant Ukrainian grid-injected biomethane less favourably than EU-origin biomethane for the purposes of counting towards renewable-energy targets/obligations.

Download Position paper (in Ukrainian)

Download Position paper (in English)

Compliance with RED III Directive

The document explains the compliance of Ukrainian biomethane injected into gas networks with the RED III Directive, namely:

• Interconnected Ukrainian gas network — Ukraine’s physically interconnected gas network should be treated as part of the EU “interconnected gas system” and, for Union Database (UDB) purposes, within the single mass-balance system;

• Recognition of Ukrainian biomethane — Biomethane supplied from Ukraine must be eligible to be counted towards the renewable energy targets of EU Member States and for other related RED III purposes on the same basis as biomethane injected into EU gas networks.

Ukrainian biomethane = biomethane from EU countries

The development of the Ukrainian biomethane sector aligns with the REPowerEU initiative, which aims to reduce dependence on fossil gas and diversify the sources of sustainable gases within the EU energy market.

As a strategic partner of the EU in the field of energy security, Ukraine has already implemented the mechanisms necessary to ensure full compliance of biomethane production and grid injection with the provisions of Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources, as amended (hereinafter – RED III).

Ukraine is part of the European energy space!

Where Ukrainian consignments are certified under EU-recognised schemes, booked in MWh at the economic operator level, and fully traceable from injection to export or domestic use, they stand in the same legal and factual position as EU-origin biomethane.

Excluding them from counting on the basis of origin alone would be an unjustified barrier that contradicts the EU and Energy Community non-discrimination and free-movement principles, and would fragment the single logistical system recognised in EU and Energy Community legislation – absent any objective, evidence-based and proportionate justification (which is not present where Ukraine meets identical sustainability and quality requirements).

Ukrainian biomethane has the potential to make a significant contribution to the EU’s objectives of decarbonisation, diversification of energy sources, and strengthening of energy security.

Ensuring unhindered access of Ukrainian biomethane to the EU market would increase the supply of sustainable gases, alleviate price pressure on consumers, and stimulate investment in infrastructure.