SEA-LNG coalition calls on EU to protect mass-balance chain of custody under RED III
In the UK, industry coalition SEA-LNG is urging the European Commission’s Directorate-General for Energy (DG ENER) to protect the mass-balance terminal chain of custody. This comes ahead of expected proposed revisions in 2026 to the implementing framework for the Renewable Energy Directive (RED III).
In SEA-LNG’s latest report, ‘Liquefaction by Equivalence Pathways for Liquefied Biomethane: A Policy Framework to Enable Scalable Maritime Decarbonization’, SEA-LNG argues that liquefied biomethane (LBM), delivered via mass-balance terminal pathways using liquefaction by equivalence, is the lowest-cost and lowest-emission chain of custody for compliance under FuelEU Maritime and EU ETS.
According to SEA-LNG analysis, LBM bunker volumes grew approximately 100-fold in 2025 compared with 2024, with the overwhelming majority delivered via mass-balance terminal pathway. It can leverage Europe’s existing network of more than 33 LNG import terminals and around 200,000 km of gas transmission infrastructure, without requiring new capital investment in liquefaction plants.
DG ENER is currently preparing proposed revisions to RED Annex V, Annex VI and Implementing Regulation (EU) 2022/996, all of which will be binding on Member States and will determine the legal status, GHG accounting treatment and commercial viability of the mass-balance terminal chain of custody. SEA-LNG warns that inadvertent restriction of the pathway through narrow definitions, inflated default emission factors, or inconsistency between the instruments could reduce the availability of compliant low-carbon marine fuel and raise costs for European shipping.
Category: Policy
