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31 March 2020

Feedback to the Revision of the Energy Taxation Directive

NGVA Europe represents an industry that is fully committed to the objectives of the Green Deal. In this perspective, NGVA Europe stresses that clean fuels - such as natural and renewable gas – are essential solutions to decarbonise transports and to reach the emissions reduction targets. Renewable gas, especially biomethane, has a prominent role to play since fully compatible with current natural gas technologies, meaning that it can be blended at every ratio and directly used on vehicles or injected in the grid.

Hence, NGVA Europe formulates a series of recommendations for the revision of the Energy Taxation Directive. These recommendations aim at better supporting alternative fuels to steer their environmental benefits and to ensure consistency among the ETD and other EU climate policy objectives.

NGVA Europe suggests the followings:

  • The ETD should allow to apply a preferential taxation level linked to the contribution towards a low emissions mobility. This would guarantee the promotion of the clean alternative fuels, and therefore better coherence with the Alternative Fuels Infrastructure Directive (DAFI). It would also boost the promotion of the most performing renewable and low emissions energies.
  • The level of taxation should also consider the level of market penetration specified per sector of application (and not limited to heating) in order to promote alternative fuels. This will ensure consistency with other pieces of European legislation, specifically with the Alternative Fuels Infrastructure Directive.
  • The ETD must maintain a level playing field with regards all type of fuels. If minimum taxation rate should apply to all fossil fuels, then the same principle should equally find application for electricity, without discrimination about its use in different sectors. In other terms, minimum level of taxation should equally be introduced for this type of energy in the annex dedicated to its usage as a motor fuel, rather than only in the annex addressing the heating use (Annex I, table C).
  • The review of sectoral tax differentiation is required to meet EU climate objectives. At the moment, only gas oil can get a differentiated tax rate depending on the private or commercial usage (article 7 §2). For the sake of consistency, this option should be extended to all fuels listed under the AFI Directive. Likewise, all public transport passengers and not only local public transport passengers should benefit of a differentiated taxation rate (article 5) to drive the uptake of alternative fuels.


Background information about this can be found on the website of the European Commission here.

Our feedback document can be downloaded clicking below or here.

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