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On January 2026, the European Renewable Gas Registry (ERGaR) submitted feedback to the European Commission as part of the public consultation on the draft Delegated Act revising Annex V and VI of the Renewable Energy Directive (RED). The revision of these Annexes will directly affect how the emissions of biogas & biomethane pathways are calculated and compared across Member States. While ERGaR welcomed the overall direction of the draft, it identified a number of points where additional clarification and targeted changes are needed to better reflect how the biomethane market actually operates. ERGaR’s input focused on improving legal clarity and consistency, keeping the rules workable and proportionate, and promoting harmonised approaches that support a European biomethane market and cross-border trade. 

Key areas of intervention 

• Liquefaction, compression and terminal models 

 
ERGaR welcomed the introduction of a harmonised default value for biomethane liquefaction. However, the Commission is encouraged to clearly confirm that this value is optional and that duly substantiated actual values can always be used. This is important to avoid creating a de facto fixed value that could penalise efficient plants and reduce incentives to invest in low-carbon liquefaction. ERGaR also requested explicit recognition and consistent treatment of liquefaction by equivalence models, and alignment between the Annexes and the Union Database (UDB). As a result, regulatory uncertainty is avoided, which could disrupt existing terminal operations and cross-border bio-LNG trade. 

• Co-digestion and CI calculation 

 
ERGaR supported the effort to harmonise co-digestion rules but highlighted that a purely average-based approach hides significant differences between feedstocks. It therefore proposed allowing, alongside the weighted average method, a feedstock-specific allocation option where robust and auditable mass-balance systems are in place. This would allow the framework to better reflect the real climate performance of different substrates, such as manure and specific waste streams. ERGaR also suggested simplifying and clarifying parts of the average methodology to reduce complexity and uncertainty for operators and auditors. 

• Standard values and methodological clarity 

 
ERGaR welcomed the expansion of standard values and underlined their importance for reducing administrative burden and enabling broad participation in the biomethane market. It requested targeted extensions to better cover real feedstock portfolios and the introduction of conservative “worst-performing feedstock” values to ensure continued usability where specific substrates are not listed. Beyond the values themselves, ERGaR called for clearer definitions of process boundaries (notably for liquefaction), improved transparency in how standard values are constructed and greater internal consistency in the tables and formulas. 

• Use of default values and process energy 

 
ERGaR raised concerns about the wording related to the use of own biogas or biomethane as process energy. It asked the Commission to clarify that default values should remain available to all biomethane producers. Moreover, only the actual process-energy component should need to be adjusted where other energy sources are used. This clarification is needed to avoid unintentionally excluding many existing and future installations from using default values. 

• Treatment of electricity accounting and alignment with RFNBO Delegated Act 

 
ERGaR highlighted that, under the draft Annexes, electricity used in biomethane production must be calculated using the regional grid-average emission factor, even where producers source renewable electricity through Power Purchase Agreements (PPAs). This differs from the RFNBO Delegated Act, which allows renewable electricity supplied under PPAs, and under additionality rules, to be recognised. ERGaR noted that this creates inconsistent GHG accounting within the same installations. The same electricity can be treated as renewable for RFNBO production, but as grid electricity for biomethane upgrading or CO₂ processing. 

To address this, ERGaR proposed introducing an explicit optional pathway. This would allow biomethane producers, under clear and auditable conditions, to apply a renewable-electricity-based methodology alongside the default grid approach. The objective is to ensure consistent treatment across renewable fuel pathways and to avoid distortive outcomes for integrated projects. 

• Downstream emissions and responsibility along the value chain 

 
ERGaR requested clear confirmation that downstream emissions (such as later compression, liquefaction, transport or bunkering) should be accounted for by the operators performing those activities, rather than being imposed on biomethane producers. This would align emissions accounting with operational control and reduce administrative burden for producers 

• Methane leakage, electricity factors and key definitions 

 
ERGaR called for clearer wording and concrete technical criteria for the methane leakage improvement factors. This is needed to ensure they are applied in the same way across Member States and can be properly audited. ERGaR also asked the Commission to clarify what is meant by “regional” electricity emission intensity, to avoid different interpretations and inconsistent results. 

In addition, ERGaR requested clearer rules on the fossil fuel comparator and a clear definition of “biowaste.” It also asked the Commission to clarify the purpose of the new correction factors or to remove them where they are not technically relevant for biomethane. 

Conclusions 

Through this contribution, ERGaR aims to support a GHG accounting framework that is robust, transparent and workable for the European biomethane market. The proposed clarifications on defaults and actual values, the recognition of grid-based and equivalence models, improvements to co-digestion rules, and better alignment on electricity, downstream emissions and methane leakage would provide a more stable and investment-grade basis for biomethane projects. 

The objective is a regulatory framework that safeguards environmental integrity, while actively enabling cross-border trade. ERGaR wants rules that support mutual recognition between Member States and make it easier to integrate biomethane and other renewable gases into the European energy system. This is essential if biomethane is to deliver its full contribution to decarbonisation, energy security and the development of a truly European renewable gas market.