REPowerEU and biomethane: Ukrainian resource in a common energy strategy

27 May 2025 - Energy Alert

On 6 May 2025, the European Commission unveiled the updated REPowerEU roadmap (COM/2025/440) (the “Roadmap”), an initiative launched on 18 May 2022 in response to russia’s invasion of Ukraine. The primary goal of this roadmap is to completely stop importing Russian fossil fuels (gas, oil and nuclear fuel) by the end of 2027. The roadmap outlines nine key steps. In particular, the relevant legislative proposals are expected to be submitted in June 2025, and by no later than 2027, the purchase of Russian gas through existing long-term and spot contracts will be completely phased out.

The planned measures include the following:

action 1 — introduction of European Union (EU) regulations obliging importers to disclose information on contracts for the supply of Russian gas, as well as setting up a regular data exchange between customs and relevant authorities of the member states;

action 2 — development of national plans for phasing out Russian gas, including clearly defined measures and timelines to be submitted by the end of 2025;

action 3 — implementation of a ban on imports of Russian gas under new contracts and under existing spot contracts by the end of 2025, and under long-term contracts by the end of 2027;

action 4 — analysing opportunities for demand aggregation and removing remaining regulatory and market barriers to optimise infrastructure usage;

action 5 — introducing trade restrictions on the import of enriched uranium from Russia to encourage the development of the EU nuclear sector , along with imposing bans on new contracts involving the Euratom Agency;

action 6 — preparing national plans member states to cease the import of Russian nuclear materials with a defined timeframe;

action 7 — launching the European initiative to establish a “radioisotope valley”;

action 8 — preparation by two member states of national plans to phase out imports of Russian oil by the end of 2027 (plans to be submitted by the end of 2025);

action 9 — continuing the enforcement and monitoring of sanctions against organisations and vessels involved in the transportation of oil from Russia that are suspected of violations.

According to the Roadmap, the EU is expected to be able to replace up to 100 billion m³ of natural gas by 2030, with a projected demand reduction of 40–50 billion m³ already by 2027. At the same time, by 2028, the EU plans a significant increase in liquefied natural gas (LNG) import capacity — approximately 200 billion m³, which is five times the current volume of Russian gas imports to the EU.

Biomethane will play a special role in the substitution process: according to the RePowerEU plan, the EU aims to produce 35 billion m³ of biomethane annually by 2030. Ukraine is also actively contributing to this process. Experts estimate that Ukraine could produce more than 20 billion m³ of biomethane annually in the future. Already this year, if all the planned plants are launched, Ukraine will be able to produce more than 100 million m³ of biomethane per year.

Today, Ukraine has already established a comprehensive legislative framework for biomethane exports, and this mechanism is being successfully implemented in practice. The rulemaking process took a considerable time and included the adoption of several important laws and regulations:

on 21 October 2021, Law of Ukraine No. 1820-IX came into force, which for the first time established biomethane as a separate object of legal regulation in the energy sector;
on 27 July 2022, the Cabinet of Ministers of Ukraine adopted Resolution No. 823, which approved the Procedure for the functioning of the biomethane register, defining the legal basis for its accounting and verification;
on 2 August 2022, the NEURC adopted Resolution No. 847, which introduced amendments to the gas transmission and distribution system codes, effectively granting biomethane access to Ukraine’s gas transmission infrastructure;
on 3 March 2022, the Ministry of Energy issued Order No. 99, which banned the export of natural gas, effectively blocking the export of biomethane due to its physical similarity to natural gas. Although this order expired on 15 June 2022, legal uncertainty regarding the customs clearance of biomethane remained;
on 16 May 2024, Law of Ukraine No. 3613-IX came into force, amending the Customs Code and clearly regulating the customs clearance procedures for biomethane for the first time, including the use of a periodic customs declaration;
on 1 August 2024, the Ministry of Finance issued Order No. 380, which clarified the procedure for declaring biomethane, specified the list of required documents and simplified the verification of its sustainability and origin.

As a result, on 6 February 2025, the Energy Customs of Ukraine issued the first periodic declaration for the export of biomethane via pipeline to the EU. The volume of deliveries was 67 thousand m³. On 11 February, another Ukrainian company exported 27.4 thousand m³. Biomethane exports from Ukraine are ongoing, and deliveries to European countries are gradually becoming regular.

Thus, the adoption of the REPowerEU Roadmap creates additional opportunities for Ukrainian biomethane producers, as the goals outlined in the document to replace Russian energy resources provide for a significant increase in demand for environmentally friendly fuels. Given the legal framework for biomethane production and export already established in Ukraine, as well as the first supplies to the EU, Ukrainian companies have a real chance to integrate into the European energy market and expand their export potential within the framework of the common climate and energy policy.

Read more about new developments in the energy sector in the monthly GOLAW digest.