From theory to practice: Ukraine exported its first batch of biomethane to Europe

A historic step in this direction was the launch of biomethane exports

On February 6, the Energy Customs of Ukraine issued a periodic customs declaration for the export of the first batch of biomethane to Europe via pipeline transport. The supply volume amounted to 67,000 cubic meters. On February 11, a second Ukrainian company started exporting biomethane to Europe. This time, the export volume was 27,400 cubic meters of biomethane.

This is a significant breakthrough for Ukraine’s energy sector, as the regulatory work to unlock biomethane exports lasted more than two years. To achieve this, several legislative and regulatory acts were adopted, including:

• Law of Ukraine No. 1820-IX “On Amendments to Certain Laws of Ukraine Regarding the Development of Biomethane Production”, which came into force on October 21, 2021, and established biomethane as a separate category within the legal framework;
• Resolution of the Cabinet of Ministers of Ukraine No. 823 of July 27, 2022, “On Approval of the Procedure for the Functioning of the Biomethane Register”, which defined the legal conditions for the register’s operation and ensured a verification mechanism;
• Resolution of the National Energy and Utilities Regulatory Commission (NEURC) No. 847 of August 2, 2022, “On Amendments to the Gas Transmission System Code and Gas Distribution System Code”, which unlocked biomethane access to Ukraine’s gas transmission system.

Why was biomethane export blocked?

Following the full-scale invasion, on March 4, 2022, Ukraine banned the export of natural gas (according to the order of the Ministry of Energy of Ukraine No. 99 of March 3, 2022, which was later repealed on June 15, 2022). Since biomethane is similar in characteristics to natural gas, the Energy Customs classified pipeline biomethane as natural gas, which automatically blocked its export.

Formally, there was no direct ban on biomethane exports in Ukraine. However, there were no clearly defined customs procedures, making the process unregulated from a legal standpoint.

How was diomethane export unblocked?

The first step towards solving the issue was the entry into force of Law of Ukraine No. 3613-IX on May 16, 2024, which amended the Customs Code of Ukraine to regulate customs control and biomethane clearance, eliminating legal uncertainty regarding its export. In particular, the law introduced clear procedures for the customs clearance of biomethane transported via pipeline. This allowed customs authorities to use a periodic customs declaration for its export, defined the necessary documentation, and eliminated the previous classification of biomethane as natural gas, which had blocked its export.

The final unlocking of exports became possible with amendments to customs legislation, particularly with the entry into force of Order No. 380 of the Ministry of Finance of Ukraine on August 1, 2024. These amendments clarified the biomethane declaration process, allowed the use of periodic customs declarations, defined a clear list of required documents, and simplified the verification mechanism for biomethane’s origin and sustainability.

Currently, biomethane export is possible with the necessary documentation package. Biomethane crosses the customs border based on:

• a periodic customs declaration;
• a certificate of compliance with biomethane sustainability criteria;
• documents confirming the producer’s connection to the gas system with an automatic measuring device;
• a biomethane acceptance-transfer act, signed by the producer and the gas system operator;
• a gas storage operator’s act on biomethane movement within storage facilities.

For customs clearance under export mode, the following documents are submitted:

• additional declarations with exact volume details;
• Proof of Sustainability (PoS) for biomethane;
• a general biomethane acceptance-transfer act from transporters;
• a certificate from the gas transmission system operator on biomethane supply and withdrawal records.

Next Steps: Harmonization with the EU

Despite this success, biomethane exports require further regulation. A key challenge is integrating Ukraine’s biomethane register into the European Union’s Union Database and securing EU recognition of biomethane guarantees of origin issued in Ukraine. This would streamline approval processes and integrate Ukrainian producers into the European market. However, there are no clear forecasts yet regarding the timing and conditions for implementing these steps.

Biomethane export opens new opportunities for Ukraine’s agricultural sector, biomethane producers, and bioenergy investors. This is not only a boost for agriculture (since biomethane is produced from organic waste) but also an economic incentive for biomethane producers, as exports to the EU increase profitability and drive expansion of production capacities.

Moreover, biomethane exports positively impact Ukraine’s state budget, as they generate foreign currency revenue and contribute to macro-financial stability.

This breakthrough serves as an example of successful energy policy implementation and proves that Ukraine has all the necessary conditions for a sustainable energy future.

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