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CLNR

The European Commission has published a package of recommendations to facilitate the implementation of the EU Methane Regulation while safeguarding the EU’s security of energy supply:

  • The first recommendation provides guidance on the application of Article 33 of the Regulation, encouraging Member States to adopt a proportionate and coordinated approach to enforcement by prioritising compliance support, taking account of operators’ good-faith efforts and the practical challenges associated with the first years of implementation, while allowing penalties to be applied progressively.

  • The second recommendation introduces optional model contractual clauses that EU importers and their international suppliers can incorporate into commercial contracts to facilitate compliance with the Regulation’s methane-related import requirements. The clauses aim to improve transparency, ensure the exchange of emissions data and monitoring information, clarify reporting responsibilities along the supply chain, and reduce legal uncertainty for both EU importers and third-country producers.

Together, the recommendations are intended to provide greater legal certainty, promote harmonised implementation across Member States, and support compliance with the Regulation’s import requirements without reopening the underlying legislation.