Urgent call for targeted amendments to the Methane Emissions Reduction Regulation through the EU simplification agenda including the stop-the-clock

Dear Energy Ministers,

While Europe and our companies work to secure oil and gas supply to mitigate the impact of the ongoing Middle East crisis, we wish to stress that the EU Methane Emissions Reduction Regulation (EUMR), in its current form, risks undermining the Union's energy security of supply and competitiveness.

After a joint industry effort to carefully assess possible impacts, we are concerned that significant parts of the EU's natural gas and crude oil imports may not comply with the Regulation's requirements as of January 2027 - up to 43% of the EU's natural gas and around 90% of its crude oil imports.1

This limits the EU's access to globally traded energy at a time when supply is constrained. The Regulation's uncertain and excessive penalties, up to 20% of annual turnover, is also a deterrence to European importers signing supply contracts. The Regulation's requirements are overly complicated and impossible to operationalise within set deadlines. Companies and public authorities hence, face clear legal compliance risks.

We appreciate and support the efforts of Member States and the European Commission services to address industry concerns through pragmatic implementation. However, we remain concerned they will not provide the necessary legal certainty to ensure imports are not negatively impacted, be it in terms of volumes or price.

Even in a more flexible scenario where adjustments to the Regulation are made, allowing the entire production from 5 or 10 key supplier countries (incl. UK, Norway, US, Qatar, Nigeria), the price impact would be equivalent to those witnessed on European energy markets due to the ongoing crisis in the Middle East.3

Furthermore, the Regulation also puts significant strain on the EU's domestic producers and infrastructure operators by mandating costly and non-proportional measures while yielding little benefit or potentially even a net GHG emissions increase - this could further accelerate the decline of Europe's domestic production, weaken its strategic autonomy, and make the energy transition more costly.

The oil and gas industry has made significant progress in reducing methane emissions5 and has developed recommendations for a more efficient, realistic and proportionate approach that incentivises progress and innovation and - most of all - enables compliance.

We are ready to work closely with European institutions to ensure rules that promote continued reduction of methane emissions while avoiding risks to the energy supply, affordability and competitiveness of Europe's citizens, businesses, and energy-intensive industries.

Given these risks, we urgently call for targeted amendments to the Methane Emissions Reduction Regulation through the EU simplification agenda, including the stop-the-clock mechanism as per recent requests from several Member States.

Yours sincerely,
The co-signatories

The list below is organised by alphabetical order, starting with companies and followed by trade associations.