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16 December 2020

Major inconsistencies remain for the EU Taxonomy to truly deliver for the economy and the environment

In October 2020, the European Commission published its long-awaited draft Delegated Acts (DA) setting the first technical screening criteria (TSC) that will be used by the EU Taxonomy to identify which economic activities should be labelled as making a substantial contribution towards the carbon neutrality. As a reminder, the EU Taxonomy aims at orienting private sector investments to green technologies and businesses, and as such will serve as guidance for the EU to reach the climate neutrality by 2050.

The challenging technical exercise of scanning through the 500-pages long draft DA revealed that the concerns raised by NGVA Europe in July (see article) regarding the missed opportunity of not including gas mobility within the Taxonomy have only been marginally addressed by the European Commission. The criteria are still lacking a clear rationale and suffer from inconsistencies that could be detrimental to the development of already available low emissions mobility solutions, such as natural and renewable gas-based transport.

In light of these elements, NGVA Europe has reacted and deployed the following actions:


Joint Call for an EU Taxonomy delivering for the economy and the environment

Together with 15 other EU associations, NGVA Europe co-signed a “Joint Call for an EU Taxonomy delivering for the economy and the environment” that was sent to the European Commission and to the Permanent Representations of Member States to the European Union.

This statement highlights key principles that the European Commission should follow while drafting the DA for the future Taxonomy:

  • Complementing the implementation of adopted EU climate and energy legislation already introduced to reach decarbonisation objectives.
  • The criteria and thresholds must be impact-assessed prior to their application.
  • Guaranteeing a transitional, evidence-based and pragmatic approach.



Contribution to the public consultation of the European Commission on the draft Delegated Acts

In parallel, NGVA Europe submitted its feedback on the draft DA in which more specific recommendations were formulated. These include:

  • Consistently align TSC with the existing EU legislation that has been specifically designed to decarbonise transport and  refrain from setting double standards to safeguard predictability for investments

By inconsistently cherry-pick EUstandards without a transparent rationale, the TSC would endanger the development of already available low emissions mobility solutions such as natural and renewable gas-based transport.

  • Cover the entire sustainable value chains, including all activities linked not only to the production of biomethane for transport, but also its concrete use as a fuel in road transport.

There missing link between the production and the consumption of biogas in transport remains. Indeed, the TSC exclude all types of vehicles running on biomethane/biogas and associated refuelling infrastructure from the scope of climate change mitigation activities. This inconsistency risks to turn the Taxonomy into an inefficient tool. It is also a missed opportunity to acknowledge the great contribution of biomethane to a transition to a circular economy.

  • Apply a consistent methodology to include all available sustainable technologies

As it stands, the TSC suffer from important inconsistencies and methodological flaws that prevent investors from making fully informed decisions on their investments. In the case of the transport sector, the systematic and exclusive use of a tailpipe approach to measure emissions from vehicles does not allow to reflect the real carbon footprint of the different transport technologies, and exlcudes clean and sustainable solutions like biomethane.

For more details, NGVA Europe’s feedback is available here.


Next steps:

  • The European Commission should adopt the final DA by mid-March 2021.
  • This adoption will open a so-called scrutiny period which may last between 2 and 6 months, during which the Member States and the European Parliament will be able to examine the DA and formulate modifications or objections.
  • This DA will then enter into force as of January 2022.
  • By the end of 2021, the European Commission will publish the DA defining the TSC for the remaining environment-related objectives of the EU Taxonomy.

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