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The European Commission has launched consultations on the future of the Renewable Energy Framework beyond 2030, marking the beginning of a process that will shape the next phase of Europe’s energy transition. As the EU works toward reducing greenhouse gas emissions by 90% by 2040, policymakers face a critical challenge: creating the conditions needed to scale clean energy solutions, strengthen energy security, and maintain Europe’s industrial competitiveness.
On 2 July 2026, we had the pleasure of participating in the second stakeholder workshop supporting the European Commission's Impact Assessment for the post-2030 Renewable Energy Framework. During the session dedicated to renewable hydrogen and its derivatives, including e-methane, participants discussed pathways to accelerate market uptake in the post-2030 period. The message that emerged from the discussions was clear: unlocking investment and deployment will require long-term dedicated RFNBO targets, continuity, predictability and legal certainty for investors, the creation of lead markets, a regulatory framework that reflects operational realities, and measures to address key economic barriers such as high energy costs and infrastructure constraints.
Against this backdrop, we have submitted a contribution to the Commission’s Call for Evidence, highlighting the role that renewable fuels of non‑biological origin (RFNBOs), including e‑methane, can play in supporting a cost‑effective and resilient transition. While the current Renewable Energy Directive (RED I to III) has laid important foundations, significant barriers continue to slow deployment across Europe.
For us, the post‑2030 framework represents a strategic opportunity to build on progress achieved to date and provide the long‑term certainty needed for the market to evolve. Decisions made in the coming years will influence not only the pace of RFNBO deployment, but also Europe’s ability to develop a competitive domestic renewable fuels industry and achieve its long‑term climate objectives.
The consultation comes at a pivotal moment for European energy policy. As the cornerstone of the EU’s renewable energy legislation, the Renewable Energy Directive shapes investment decisions, infrastructure development, and the deployment of clean energy solutions across the economy. The framework that will apply beyond 2030 will determine how renewable fuels contribute to the EU’s climate objectives while supporting energy security and industrial competitiveness.
This forward‑looking perspective is essential because the energy transition is advancing more rapidly than the regulatory cycle. New technologies are reaching commercial maturity, project pipelines are expanding, and the urgency of decarbonization continues to intensify. At the same time, energy infrastructure and industrial projects require long development timelines, while legislation often takes years to negotiate and implement. To build the energy system of the future, policy must anticipate emerging market realities rather than respond only to current conditions.
For this reason, discussions on the post‑2030 framework are necessary even as RED III is still being implemented across Member States. Decisions taken today will shape investment strategies and project development for decades, providing the visibility companies need to commit capital and scale renewable fuel production.
The consultation also offers an opportunity to assess lessons learned from RED III. While the current framework has laid important foundations for renewable hydrogen and RFNBO deployment, several challenges persist, including permitting bottlenecks, regulatory complexity, uneven implementation, and the limited competitiveness of renewable fuels relative to fossil alternatives. Addressing these barriers will be critical to unlocking the full potential of renewable molecules in Europe’s energy transition.
In this context, the e‑NG Coalition’s contribution underscores the need for a stable and predictable framework that supports long‑term planning across the value chain. Our response highlighted the role e‑methane can play in enabling a cost‑effective and resilient energy system and sets out recommendations to strengthen demand signals, improve regulatory clarity, and create the conditions necessary for RFNBOs to scale across Europe.
Among RFNBOs, e‑methane occupies a unique position within the European energy system. Produced through the methanation of renewable hydrogen and a sustainable carbon source, it combines the emissions‑reduction benefits of renewable fuels with the practical advantages of compatibility with existing gas infrastructure.
Unlike many emerging energy carriers that require entirely new transport and distribution networks, e‑methane can be transported, stored, traded, and consumed using existing pipelines, storage facilities, LNG terminals, and end‑use equipment. This “drop‑in” compatibility enables renewable energy to be integrated into the energy system without significant modifications to infrastructure or industrial processes.
The fuel is relevant for sectors where direct electrification remains technically difficult, economically challenging, or operationally impractical, energy‑intensive industries, long‑distance and heavy‑duty transport, maritime shipping, and other applications requiring high energy density or long‑duration storage. In these sectors, e‑methane can contribute to decarbonization while leveraging existing supply chains and established market structures.
Our submission also underlined the role e‑methane can play in supporting broader energy system integration. Through power‑to‑gas pathways, renewable electricity can be converted into a storable and transportable fuel, helping integrate variable renewable energy sources, reducing potential grid congestion, and providing long‑term energy storage capabilities.
Beyond its decarbonization potential, e‑methane can contribute to strategic objectives for the European Union by supporting diversification of energy supply, strengthening energy resilience, and reducing dependence on imported fossil fuels. Europe is already well positioned to lead the sector globally, hosting the largest number of announced e‑methane projects worldwide and representing the second‑largest projected production hub by capacity.
The current Renewable Energy Directive already recognizes the importance of RFNBOs through binding targets for renewable hydrogen in industry and dedicated RFNBO requirements in transport. Maintaining and strengthening these demand drivers beyond 2030 will be essential to unlock investment in e‑methane production and ensure that Europe can capitalize on its early leadership position.
While RED III has established important foundations for renewable hydrogen and other RFNBOs, several structural barriers continue to constrain investment and slow deployment. Without addressing these challenges, the EU risks falling short of its decarbonization objectives and losing competitiveness in the evolving global market for renewable fuels.
A central concern that we have identified is the lack of sufficiently strong long‑term demand signals. While binding RFNBO targets in transport and industry have begun to stimulate market development, investors require visibility well beyond 2030 to support projects with long development timelines and significant upfront capital requirements. Maintaining and strengthening dedicated RFNBO targets will therefore be essential.
Our submission also highlights persistent delays in the transposition and implementation of RED III provisions across Member States. Uneven implementation can weaken demand signals, create regulatory fragmentation, and slow the emergence of a functioning European market for RFNBOs.
Another significant challenge relates to governance, traceability, and accounting systems. The timely implementation of the Union Database (UDB) remains critical for ensuring transparency and traceability throughout the value chain. Additional clarity is needed regarding the treatment of liquefaction by equivalence and associated carbon‑intensity accounting rules.
The consultation response also raises concerns regarding the global competitiveness of European projects. Competing jurisdictions are deploying large‑scale support mechanisms and more flexible regulatory approaches to accelerate renewable hydrogen and derivative production. If European projects continue to face significantly higher regulatory burdens, investment and production capacity may shift outside the EU.
Finally, practical challenges have emerged during the implementation of the RFNBO Delegated Acts. Stakeholders continue to face issues related to additionality requirements, temporal and geographical correlation rules, and electricity market design constraints. A targeted review of these provisions could help facilitate project deployment while maintaining environmental integrity and legal certainty.
To ensure that RFNBOs can contribute effectively to Europe's decarbonization, competitiveness, and energy security objectives, we have outlined five key priorities for the future Renewable Energy Framework. Together, these recommendations aim to strengthen demand signals, improve regulatory certainty, and create the conditions necessary for large-scale deployment of e-methane and other renewable fuels.
The binding sector-specific RFNBO targets remain the single most important driver of market development. Existing targets under the Renewable Energy Directive have already helped establish a business case for renewable fuels in industry and transport, but additional visibility beyond 2030 will be needed to support the next generation of projects.
To provide this long-term certainty, we recommended maintaining the dedicated RFNBO sub-targets within the post-2030 framework and strengthening them over time. Specifically, it proposes increasing the transport RFNBO sub-target from the current 1% requirement to 5% by 2035 and 10% by 2040. Where higher targets may not yet be feasible, we also support the continued use of regulatory multipliers, similar to those currently used under RED and FuelEU Maritime, as a means of encouraging early market uptake.
The submission also introduces a new proposal: the creation of a dedicated RFNBO mandate for gas grids. Such a mechanism would create demand for renewable gaseous fuels across all connected end-users, including industry, heating, cooling, transport, and maritime applications. Given e-methane's ability to utilize existing gas infrastructure, we consider this approach a cost-effective pathway to accelerate decarbonization across multiple sectors simultaneously.
Importantly, we have also cautioned against replacing dedicated renewable energy requirements with a single overarching "clean energy" target that could allow renewable and low-carbon solutions to compete within the same compliance pool. According to the submission, dedicated RFNBO targets should remain clearly distinguishable and non-dilutable in order to preserve investment certainty and ensure continued deployment of renewable fuels. Low-carbon hydrogen may have a complementary role to play in specific applications but should not substitute for renewable fuels in a way that weakens demand for RFNBOs.
While renewable fuel technologies continue to mature, many projects still face economic challenges when competing against fossil-based alternatives. We have therefore argued that RFNBOs remain underexploited and require dedicated support mechanisms to achieve commercial scale.
To address this, the submission calls for targeted regulatory incentives and expanded European support schemes for RFNBO projects, including e-methane production facilities. Simplified permitting procedures are also highlighted as a priority, given that permitting delays continue to affect renewable energy and infrastructure projects across Europe. We have further emphasized the importance of cross-border cooperation mechanisms that can optimize renewable electricity availability, CO₂ sourcing, and infrastructure utilization across Member States, helping reduce overall system costs while supporting deployment.
A functioning renewable fuels market depends not only on production capacity but also on robust governance, traceability, and accounting systems. For this reason, we have identified the implementation of the Union Database (UDB) as a critical priority for the post-2030 framework.
The UDB is expected to play a central role in ensuring transparency and traceability throughout RFNBO supply chains. However, we have noted that additional regulatory clarity is still needed regarding the treatment of liquefaction by equivalence and the calculation of associated carbon-intensity values. The submission also highlights the need to recognize cross-border transfers of Guarantees of Origin and ensure their integration with sustainability certification systems in a way that avoids double counting and facilitates international trade. Resolving these issues would significantly improve regulatory certainty and support the development of liquid, functioning RFNBO markets.
Europe is competing in an increasingly global market for renewable hydrogen and its derivatives and while it has established comprehensive sustainability requirements, other jurisdictions are deploying large-scale subsidies and more flexible regulatory frameworks to attract investment and accelerate production.
To preserve Europe's competitiveness, we have called on the European Commission to ensure a level playing field between domestic production and imports. This includes addressing differences in electricity sourcing rules, certification frameworks, subsidy eligibility, and broader regulatory conditions that can influence investment decisions. Maintaining competitive conditions will be essential not only for achieving climate targets, but also for preserving industrial leadership, securing supply chains, and strengthening Europe's energy resilience.
Finally, we recommended a focused review of specific provisions within the RFNBO Delegated Acts based on lessons learned during implementation. While the current framework has established important sustainability safeguards, practical experience has revealed several provisions that may inadvertently hinder project deployment and affect investment decisions.
Particular attention should be given to requirements related to additionality, temporal correlation, geographical correlation, and electricity market design. We have emphasized that any review should remain targeted and limited in scope, avoiding broader regulatory uncertainty or retroactive changes that could undermine investor confidence. The objective should be to improve the effectiveness and scalability of the framework while preserving environmental integrity, legal certainty, and the sustainability principles underpinning the current RFNBO regime.
Taken together, these recommendations reflect a common objective: creating a post-2030 framework that provides the long-term certainty, market infrastructure, and regulatory conditions necessary to transform Europe's growing pipeline of renewable fuel projects into a mature and globally competitive industry.
As the European Commission begins shaping the post‑2030 Renewable Energy Framework, the decisions made in the coming years will have implications far beyond the next legislative cycle. For RFNBOs, including e‑methane, the challenge is no longer limited to technology development. Project pipelines continue to grow, and industrial interest in renewable molecules is increasing. The next phase will depend on policymakers’ ability to provide the regulatory certainty, market signals, and enabling conditions necessary to convert these projects into operational assets.
Achieving the EU’s 2040 climate objectives will require a framework capable of supporting investment decisions today while providing visibility for the coming decades. Binding targets, effective implementation, functioning certification and accounting systems, and competitive market conditions will all be essential.
For e‑methane specifically, the opportunity extends beyond emissions reductions. As a renewable fuel compatible with existing gas infrastructure, it can contribute simultaneously to decarbonization, energy resilience, and supply diversification while supporting the efficient use of assets already deployed across the European energy system.
The e‑NG Coalition therefore welcomes the Commission’s consultation as an opportunity to strengthen the foundations of Europe’s renewable fuels market. By maintaining robust RFNBO demand signals, addressing deployment barriers, improving regulatory clarity, and ensuring a level playing field for European projects, the post‑2030 framework can help create the conditions necessary for renewable methane and other RFNBOs to contribute fully to the EU’s climate, competitiveness, and energy security objectives.
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For more information, contact the Policy Officer in charge, Alexandra Popova, at alexandra.popova@eng-coalition.org
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