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Commission Publishes MER Implementation Recommendations: Compliance Paths and Penalty Suspension
Managing Partner Correggio Consulting BV (Brussels) Founder-CEO CorreggioNET │ Managing Director, REMITREP Services BV (Amsterdam) │ Founder ZETA (Zero Emissions Traders Alliance) (Abu Dhabi)
Region: EU | Commodity: Gas | Topic: Emissions/MER, Compliance
The European Commission has released its long-awaited recommendations on implementing the Methane Emissions Regulation (MER), covering two key areas.
On compliance, the Commission outlines how importers can demonstrate they meet their obligations. The guidance assumes a straightforward link between producer and importer in most cases. For more complex supply chains, it points to "trace and claim" and certification solutions but leaves key details unresolved: what documentation is required, and who can issue, verify, or approve it. The model contract clauses also raise questions about how "importer" responsibilities should be allocated between parties at different stages of the supply chain.
On penalties, the Commission recommends that Member States refrain from applying certain penalties for importer obligations due in 2027 to 2029, in order to avoid supply disruptions. However, the recommendation is non-binding and does not provide the legal certainty market participants would need to rely on it.
Sources: European Commission: Methane Emissions; Commission Recommendations (EU) 2026/1834 and 2026/1835
For more information on MER compliance obligations and how they may affect trading operations, please contact CorreggioNET at info@correggionet.eu.