Joint CSO letter Energy Council 25 June 2026

Dear President von der Leyen,
On behalf of the undersigned organizations, we are writing to urge the European Commission
to hold the line against attempts to weaken, reopen, or postpone Chapter V of the EU Methane
Regulation (EUMR) at this week’s Transport, Telecommunications and Energy (Energy)
Council. We welcome the European Commission’s 23 June joint statement with the United
Kingdom and Canada,1 reaffirming that methane abatement is a pillar of energy security and
ask that the Commission adheres to the goals it sets forth by protecting Europe’s most concrete
means of driving methane abatement.

A non-paper put forward by the Czech Republic and Slovakia, supported by 9 other EU
Member States and industry groups, calls for a three-year legislative postponement of core
importer requirements. Reopening or postponing this regulation agreed by co-legislators
would be a disproportionate and counterproductive response to temporary administrative
hurdles, effectively neutralizing Europe’s global leverage on climate and methane reduction
until 2029.

The administrative and market concerns being raised to justify this delay are factually flawed
and can be resolved through immediate Commission guidance, without altering the legislative
text:

• Implementing acts and secondary legislation are not a bottleneck: The non-
  paper argues that the absence of secondary legislation under Article 28(6) regarding
  MRV equivalency creates a compliance bottleneck. This is legally incorrect. No third
  country is currently presumed to have regulatory equivalency. The baseline obligations
  under Articles 27 and 28 provide two other pathways for MRV equivalency (at the
  producer level by either meeting Article 12 or OGMP 2.0 Level 5), which do not require
  implementing acts to function. For the purpose of reporting, importers can ensure
  compliance by requiring producers to meet these standards and share their empirical
  data.
• The key challenge regarding verification is administrative and easily
  resolved: National Accreditation Bodies (NABs) are hesitating to accredit
  independent verifiers because they lack an approved EU framework for Article 12
  verification that satisfies the requirements of Articles 8 and 9. The Commission has the
  explicit authority under Article 8 (3) to provide guidance on verification activities.3 By
  issuing a Commission guidance indicating that the criteria are met by an existing
  international standard, such as the Energy Emissions Modelling and Data Lab
  (EEMDL) protocol, the Commission can give competent authorities and NABs the
  certainty to unlock the accreditation pipeline within months, not years.
• Energy security claims contradict market reality: The non-paper makes
  incorrect statements about cost and energy security impacts that rely on false
  assumptions that large volumes of fuels will require strict traceability requirements.
  The European Commission has clearly communicated that it will not apply these
  traceability requirements,4 rendering the conclusions of the Wood Mackenzie study
  invalid.5 Rystad Energy finds that global OGMP 2.0 Level 5 volumes are expected to be
  three times EU demand by 2027.6 Separate energy security concerns regarding cost
  impacts are overstated. Independent modelling by Rystad Energy shows that a phased
  EUMR performance standard will cost an average of just €0.07/MMBtu for gas and
  €1.33/barrel for oil,7 costs that are an order of magnitude lower than standard
  geopolitical price volatility8 and entirely negligible to global suppliers.

Allowing a legislative rollback would reward historical inaction by international producers,
penalize the proactive operators who have already invested in robust monitoring, and leave
EU domestic producers operating on an unequal playing field. Furthermore, it would
undermine the very legal certainty that companies wish to strengthen.