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.
The position paper was prepared with the participation of UABIO members. The document highlights issues related to Ukrainian biomethane access to EU markets.
UABIO believes that EU Member States should not treat Ukrainian biomethane injected into the network less favourably than biomethane originating in the EU for the purposes of meeting renewable energy targets/commitments.
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.
RED III compliance in practice
Biomethane Metering (Unit Consistency)
All certified biomethane produced in Ukraine is recorded and traded in energy units (megawatt-hours, MWh, or megajoules, MJ) from the moment of injection into the grid to the point of export. This practice ensures consistency between energy content and volume units across the entire chain, fully satisfying the requirements of RED III, Commission Implementing Regulation (EU) 2022/996, and the relevant EU-recognised voluntary certification schemes (such as ISCC EU). In other words, every unit of biomethane is tracked by its energy content throughout its journey from the Ukrainian producer to the EU importer.
Domestic Withdrawals (Traceability of Internal Consumption)
Any certified biomethane withdrawn for use inside Ukraine remains fully traceable and cannot be double-counted. When a withdrawal occurs, the associated PoS is transferred to the domestic buyer:
- If the buyer is not certified under an EU-recognised voluntary scheme, the PoS is immediately marked as withdrawn in the producer’s scheme registry and booked out from the mass balance, ensuring it cannot be resold or exported.
- If the buyer is certified, the PoS stays active and may later be transferred or cancelled when the buyer claims a renewable-energy benefit (for example, once Ukraine introduces its own quota scheme).
Ukraine’s delivery on withdrawals
The Ukrainian gas grid provides precise volumetric metering (m³) and official gas quality data (including calorific value (CV)/energy density).
Ukraine has adopted EN ISO 6976:2020 for calculating calorific value and converting m³ <-> kWh, the same methodology used in the EU. Economic operators can therefore reliably account for biomethane in MWh, as required by the EU-recognised voluntary schemes and REDIII, by converting metered m³ to energy units and verifying the calculation with official documents issued by DSOs and the TSO.
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).
Download Position paper (in Ukrainian)
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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.