Europaudvalget 2025
KOM (2025) 0828
Offentligt
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EUROPEAN
COMMISSION
Strasbourg, 17.6.2025
SWD(2025) 830 final
COMMISSION STAFF WORKING DOCUMENT
Assessing the impact of measures to phase out Russian gas imports and improve the
monitoring of potential energy dependencies and amending Regulation (EU) 2017/1938
Accompanying the document
Proposal for a Regulation of the European Parliament and the Council
on phasing out Russian gas imports, improving the monitoring of potential energy
dependencies and amending Regulation (EU) 2017/1938
{COM(2025) 828 final}
EN
EN
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1. Objectives
The “Roadmap towards ending Russian energy imports” (‘Roadmap’) adopted on 6 May
2025 builds on the EU's immediate response to tackle the consequences of Russia's illegal
invasion of Ukraine, including the REPowerEU
1
plan, and the significant progress made
within three years to diversify away from Russian energy by implementing REPowerEU
2
, the
green transition and sanctions.
Despite the progress, EU energy imports from Russia remain in the Union’s energy system.
This poses a threat to the EU’s energy and economic security. The Roadmap sends a clear
signal to markets and alternative suppliers that the EU is fully committed to stop relying on
Russian energy and therefore putting an end to being subject to potential coercive actions of
the Russian Federation.
The present staff working document accompanies the Commission Proposal for a Regulation
of the European Parliament and of the Council on phasing out Russian gas imports,
improving monitoring of potential energy dependencies and amending Regulation (EU)
2017/1938 (COM (2025) 828). It assesses the expected impact on the affected markets and
recalls the objectives of the proposed measures.
2. Russia’s weaponisation of the energy sector
Russia has a history of threatening the EU’s security of supply by unilaterally cutting gas
flows to Europe.
The first episode dates back to early 2006 when, following a commercial dispute between
Gazprom and Ukraine, deliveries to Ukraine were cut significantly. On 2 January 2006,
several European countries reported a cutback of gas deliveries due to reduced feeding-in
from Russia. The drop was considerable: Hungary was reported to have lost up to 40% of its
Russian supplies; supplies to Austria, Slovakia and Romania were down by one third, France
and Italy by 25-30% and Poland by 14%.
3
Withdrawals from storage and voluntary fuel
switching made up for the supply reduction. As the disruption lasted just a few days, no
interruption of supplies to final customers in the EU was reported. However, as noted by the
IEA
4
: “The
dispute and consequent interruptions did cause serious concerns over security of
supply and gas dependence on Russia in many European countries”
and it shows how
“Gazprom is clearly prepared to use harsh tactics to enforce higher prices”.
In the aftermath
of the dispute, a number of measures were discussed to improve the security of supply in the
regions, including increased strategic gas stocks, diversification of the fuel mix,
diversification of gas supply by calling on other pipeline gas suppliers, increased fuel-
switching capacities, energy efficiency, and more. For example, in 2007, the Commission
1
2
COM(2025) 440 final.
EUR-Lex - 52022DC0230 - EN - EUR-Lex.
3
Stern, J. (2006), Natural Gas Security Problems in Europe: The Russian-Ukrainian Crisis of 2006, Asia-Pacific
Review 13, 32-59.
4
IEA, Natural gas market review 2006,
https://iea.blob.core.windows.net/assets/51e7a259-4111-4def-8244-
ece1e5c840f0/NaturalGasMarketReview2006-TowardsaGlobalGasMarket.pdf
1
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Communication for an energy policy for Europe
5
stressed the necessity to promote diversity
of supply with regard to source, supplier, transport route and transport method in view of the
high or complete reliance of some Member States on one single gas supplier.
The Russian weaponisation of energy was observed again in January 2009 when Russia cut
off all gas supplies transiting through Ukraine for two weeks, leading to the largest
interruption of gas supply in EU history. This came at a time of very high peak gas demand in
Western and Central Europe, with the coldest weather in two decades. The gas disruptions
resulted in the most serious gas supply crisis to hit the EU in its history until 2022, depriving
EU Member States of 20% of their gas supplies (30% of imports). A total of 12 Member
States and Member Countries of the Energy Community were affected, and there were
significant economic repercussions in several Member States.
6
Figure 1
: Russian gas volume not delivered during the 2009 crisis
Source: IEA, Natural Gas Market Review, 2009
* Austria estimated
Western countries were in general able to meet the demand without interruptions to users
through a variety of mechanisms, including increased supply from other countries, stock
drawdown, voluntary and involuntary demand reductions in industry and consumer sectors,
and fuel switching in the power sector. However, this was not the case in the Central-Eastern
region, “with
industrial supplies interrupted in several countries and households as well.”
7
Major disruptions were recorded in Bulgaria, Romania, Croatia and in neighbouring
countries, such as, for example, Serbia and Bosnia and Herzegovina.
8
The consequences were
particularly severe in the Balkan countries which experienced a humanitarian emergency as
5
6
COM(2007) 1 final.
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2007:0001:FIN:EN:PDF
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52009SC0977
7
https://iea.blob.core.windows.net/assets/a099151f-4141-43ed-a797-
7eddcfec92a0/NaturalGasMarketReview2009.pdf
8
Aleksandar Kovacevic, The Impact of the Russia–Ukraine Gas Crisis in South Eastern Europe, Oxford Energy
Institute, 2009
2
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part of the population could no longer heat their homes at the peak of the winter season. In
total, according to the IEA,
9
"some
5 bcm of transit gas supplies had not been delivered over
a two-week period, plus around 2 bcm of Ukrainian supplies”.
This crisis led to the creation
of the first stepping stone in the EU’s gas security of supply framework. In its second
strategic energy review
10
, the Commission proposed an EU energy security and solidarity
action plan, focusing notably on the infrastructure needs and the diversification of energy
supplies and on strengthening oil and gas stocks and crisis response mechanisms.
Five years later, in March 2014, Russia annexed Crimea and seized Ukrainian gas production
assets. In April 2014, Putin declared in an open letter that Europe faced an increasing risk of a
new gas supply crisis and threatened to halt gas supplies to Ukraine. While no interruption to
the flow to the EU occurred, Gazprom increased prices for Ukraine and another dispute
between Gazprom and Naftogaz led to the disruption of supplies to Ukraine on 16 June 2014.
Some Member States tried to supply Ukraine by reselling gas purchased from Russia, but
Russia, as a retaliatory measure, cut supplies to Poland, Slovakia, Romania and Austria which
eventually reduced or halted the reverse flow towards Ukraine.
11
Table 1: Russia’s retaliation against EU Member States in 2014 – estimated supply cuts
Source: De Micco (2014): “A cold winter to come? The EU seeks alternatives to Russian gas” – European
Parliament – Directorate-General for External Policies – Policy Department
9
https://iea.blob.core.windows.net/assets/a099151f-4141-43ed-a797-
7eddcfec92a0/NaturalGasMarketReview2009.pdf
10
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0781:FIN:EN:PDF
11
De Micco (2014): “A cold winter to come? The EU seeks alternatives to Russian gas”, DIRECTORATE-
GENERAL FOR EXTERNAL POLICIES, Policy Department.
3
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In the past, Russia’s State-controlled monopoly exporter Gazprom has been the subject to
several Commission investigations for a possible breach of the EU competition rules and has
subsequently modified its conduct on the market to address the Commission’s competition
concerns. The competition issues at stake concerned, in several cases, so-called ‘territorial
restrictions’ in Gazprom’s gas supply contracts, prohibiting the resale of gas outside the own
country
12
, as well as evidence that Gazprom was engaged in unfair pricing practices and
made energy supplies dependent on political concessions from participation in Russian
pipeline projects or acquiring control over Union energy assets
13
.
The 2021-2022 crisis is the ultimate example of how dependency on Russia’s supply carries
dramatic risks for the EU security of supply. The crisis was caused by Russia’s manipulation
of the gas markets mainly through supply cuts that were initiated in 2021 and continued
throughout 2022. In 2021, at a moment when demand was growing significantly in the
aftermath of Covid-19, Russia first reduced gas supplies across distinct episodes, to Poland
and Germany via Yamal, but also to Slovakia and Hungary. Gazprom halted selling volumes
at EU gas hubs
14
and from mid-October 2021, Gazprom fully discontinued the use of its own
sales platform. Second, Russia lowered injections in the European storages that were under
the ownership or contractual control of Gazprom. As reported by ACER,
15
“at
the end of
October 2021, Gazprom storage stocks were at an unprecedented low level of 25%, which
was three times lower than the average of the rest of the EU facilities”.
ACER estimated that
“half
of the storages’ filling gap on 31 October 2021, in comparison to the five-previous
years, must be at least attributed to Gazprom’s behaviour”.
This led to the EU reaching only
75% of storage filling on 1 October 2021, the lowest historical level. Following the full-scale
invasion of Ukraine in February 2022, Russia responded with a series of disruptions of gas
deliveries to its EU customers. For example, in April 2022, Gazprom halted deliveries to
Poland and Bulgaria, following a unilateral change in contractual terms by Russia. Finland
was also cut off in May 2022 after applying for NATO membership. In June-July 2022 Russia
first reduced and eventually shut down entirely Nord Stream 1.
12
See for the competition investigations concerning territorial restrictions between 2003 and 2005 see:
ec.europa.eu/commission/presscorner/detail/en/ip_05_710;
ec.europa.eu/commission/presscorner/detail/en/ip_03_1345;
ec.europa.eu/commission/presscorner/detail/en/ip_05_195;
for the investigation in the Gazprom II case, see Commission Decision C(2018) 3106 final of 24 May 2018
relating to a proceeding under Article 102 of the Treaty on the Functioning of the European Union (TFEU) and
Article 54 of the EEA Agreement, Case AT.39816
–
Upstream Gas Supplies in Central and Eastern Europe.
13
See
https://ec.europa.eu/commission/presscorner/detail/en/memo_15_4829
See
https://ec.europa.eu/commission/presscorner/detail/en/memo_15_4829
14
ACER
“European
gas market trends and price drivers 2023 - Market Monitoring Report” (para. 28).
15
ACER “European gas market trends and price drivers 2023 - Market Monitoring Report”
4
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Figure 2: Gas in storage (%) in Gazprom Storages vs non-Gazprom storages
Source: JRC, 2024.
While the existing infrastructure at the time allowed Member States to face these hostile
supply cuts from Russia in 2022, such conducts by Russia cast great uncertainty on the
possible scarcity of gas in Europe and their impact on prices was unprecedented. Pre-crises,
average spot gas prices in Europe fluctuated around 15-20 €/MWh. As of mid-2021, prices
started rising well above this level (more than 70 €/MWh in the second half of 2021). The
situation further deteriorated in 2022 and saw the prices progressively increasing and
reaching levels above 300 €/MWh in summer 2022.
5
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Figure 3: TTF day-ahead prices vs Russian pipeline imports to the EU, 2022
Source: ACER - “European gas market trends and price drivers 2023 - Market Monitoring Report”
The average gas spot price in 2022 was 125 €/MWh, 6 to 8 times higher than pre-crisis. The
effects of the crisis were felt across the EU. Even those Member States – in the South-Eastern
region – which did not experience any direct disruption of the gas flow from Russia were
equally affected by the crisis and saw prices spiking to unprecedented levels. For example,
the average prices in the Austrian, Czech and Slovakian gas hubs in 2021 and 2022 were very
close to the average prices observed on the Dutch TTF, the EU gas benchmark (see Figure 4).
Figure 4: TTF prices vs gas prices in Austrian, Czech and Slovak hubs, 2021 – 2022
6
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The consequences of the gas crisis provoked by Russia spun to the electricity sector as gas
generation often represent the price setting technology in the electricity wholesale markets.
16
Electricity wholesale prices in Europe skyrocketed at the worst moments of the crisis in
August 2022 to average more than 400 €/MWh, with short-lived peaks of few days in most
countries well above 500 €/MWh. In 2022, average wholesale electricity prices were 185
€/MWh, almost 100 €/MWh more than the average price of 2021.
Figure 5: TTF vs electricity prices, March 2021- May 2025
Source: DG ENER based on S&P Global Platts
Note: Gas wholesale prices are TTF month-ahead. Electricity wholesale prices correspond to the weighted
average prices of main EU electricity markets (DE, ES, FR, NL) and Nordpool market (NO, DK, FI, SE; EE, LT,
LV)
The EU wholesale energy market suffered serious repercussions; these soon trickled down to
the retail markets and final consumers. Consequently, energy prices were the most important
driver of the significant increase in inflation, which at its peak reached levels above 10% in
2022.
16
Gasparella A., Koolen D. and Zucker A., The Merit Order and Price-Setting Dynamics in European Electricity
Markets, European Commission, Petten, 2023, JRC134300
7
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Figure 6: EU gas and electricity prices, 2021-2025
Source: VaasaETT
Concerns about Russia’s cut of existing supplies affected also the nuclear sector. Figure 7
below shows that spot prices for uranium conversion more than doubled in the space of a few
months after February 2022 and have remained at, or above, 40 $/KgU since. The prices for
uranium enrichment
17
experienced a similarly drastic increase after the Russian invasion of
Ukraine, rising from 60 $ to more than 130 $.
Figure 7: Uranium conversion price trends (in USD)
Source: Euratom Supply Agency annual report 2023
17
Separative Work Unit (SWU)
8
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Figure 8: Monthly spot and long-term SWU prices (enrichment) (in USD)
Source: Euratom Supply Agency annual report 2023
The oil market was hit by the crisis too. Russia was the largest exporter to the EU with a
share of 27%. When Russia invaded Ukraine the prices of crude oil started raising quickly out
of fear of disruptions to Russia’s supplies to the EU, peaking at almost 140 $/barrel and
remaining stably above 100 $/barrel until September 2022 (see Figure 9).
Figure 9: Brent prices – 2021-2022
160
140
120
100
Russia's
invasion of
Ukraine
$/barrel
80
60
40
20
0
04/01/2021
04/02/2021
04/03/2021
04/04/2021
04/05/2021
04/06/2021
04/07/2021
04/08/2021
04/10/2021
04/11/2021
04/12/2021
04/01/2022
04/02/2022
04/03/2022
04/04/2022
04/05/2022
04/06/2022
04/07/2022
04/08/2022
04/09/2022
04/10/2022
04/11/2022
04/09/2021
Source: S&P Commodity insights
3. Current situation and need for action
3.1.
Natural gas
Before the crisis, the EU used to import more than 150 bcm/y from Russia. Between 2021
and 2023, the EU reduced Russian gas imports by over 70% to 43 bcm/y. In 2024, this
9
04/12/2022
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downward trend stopped and imports from Russia increased somewhat, while remaining
significantly below the pre-war levels of dependency. LNG imports grew by 12% compared
to 2023, from 18 bcm/y to 20 bcm/y, and pipeline by 26%, from 25 bcm/y to 32 bcm/y.
Several Member States have taken early actions to reduce or even ban Russian gas imports,
including by terminating existing contracts with Russian gas suppliers
18
. However, even after
the end of Russian gas transit through Ukraine in 2025, Russian gas is estimated to represent
still around 13% of the EU’s overall gas imports in 2025.
19
Figure 10: Russian imports into the EU: Pipeline and LNG (volumes and share of total EU
gas imports)
Source: DG ENER based on LSEG and ENTSOG
Despite the substantial reduction in the dependency on Russia, the EU remains at risk. The
volume sourced from Russia should not be considered negligible. While the EU can replace
Russian gas without risks for security of supply if the phase out is anticipated and well-
planned in advance (see Section 4.3.1), a sudden and unexpected halt of this volume would
still be capable to cause security of supply concerns in the short term. Any volume shift to
alternative suppliers of such magnitude (approx. 35 bcm per year) would require some time
for the industry to adapt, both logistically and commercially. The end of the transit of Russian
gas via Ukraine shows how the anticipation and preparation by the Commission and the
concerned Member States was important to avoid risks for the security of supply. Thanks to
proactive measures and collaborative efforts, the EU was well-equipped to handle the
transition. In an assessment conducted in late 2024
20
, the Commission indicated that the
impact of the end of transit via Ukraine on the EU's security of supply was expected to be
limited. The 14 billion cubic meters per year still transiting via Ukraine could be fully
replaced by LNG and non-Russian pipeline imports via alternative routes, demonstrating the
flexibility and resilience of the European gas infrastructure. A meeting of the Gas
18
Estonia, Lithuania, Latvia, Denmark, Finland, Sweden, Germany, Poland, Croatia, Malta, Ireland,
Luxembourg, Austria and Czechia have prohibited or stopped gas supplies from Russia. Some Member States
could, however, be indirectly supplied with gas of Russian origin through wholesale market purchases.
19
In the first quarter of 2025, the share of Russian supply in the EU imports was 14%.
20
End of transit via Ukraine – Information from the conclusions of the Commission’s assessment
10
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Coordination Group
21
on 2 January 2025 confirmed that no concerns related to the security of
gas supply had been identified with the stop of Russian gas flows to the EU. Absent such
proactive planning and coordination in phasing-out Russian gas, the EU could be vulnerable
to Russia’s sudden supply disruptions.
The reliance on Russian gas also raises price risks. Despite the significant drop since the peak
of the crisis in 2022, prices remain higher and more volatile than pre-crisis (see Figure 11),
and the EU is now more exposed to the LNG global market and as a consequence to shocks
occurring in other regions of the world (LNG share in the EU mix doubled since the crisis,
from about 20% to 40%). In this context, Russian unpredictability and long history of
attempts to weaponise the energy sector for geopolitical purposes creates additional
uncertainty and risks. This in turn translates into higher volatility and thus higher hedging
costs for market operators.
22
Figure 11: TTF price volatility over time
Source: European Commission based on S&P Global (published in The future of European competitiveness,
Part B | In-depth analysis and recommendations)
Note: TTF month ahead, %
In view of the above, the Commission considers it of paramount importance to phase out all
the remaining natural gas import volumes from Russia. These volumes, however, are not
expected to be eliminated without further action at the European and Member State levels,
either because the majority of imports come under long-term contracts, which often envisage
take-or-pay obligations that cannot be waved without incurring litigation risks (see Section
4.4), or because Russia, in an attempt to preserve its share of supply to the EU, may sell
certain volumes at large discount, thereby discouraging European companies to look for
alternative sources. By imposing a firm halt to Russian gas imports, the trade measures
included in this proposal enable to overcome these obstacles.
21
22
Commission and Member States confirm no gas supply concerns in the New Year - European Commission
Europe’s Rising Gas-Hedging Costs Show Supply Fears Persist - Bloomberg
11
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3.2.
Nuclear
In the EU, net nuclear power production of 617 TWh contributed 24% to the overall power
mix in 2024 (see Figure 12). There are 101 nuclear power reactors operating in 12 EU
Member States with a combined net electrical generation capacity of 98 GWe, of which 19
reactors are Russian-designed
pressurised water reactors
(‘VVER’) with a total capacity of
ca. 11.5 GWe. The VVER reactors are located in five Member States: Bulgaria, Czechia,
Finland, Hungary and Slovakia. Further, there are three VVER reactors in construction at
different stages of completion in Hungary and Slovakia.
Figure 12: The share of nuclear in
the electricity mix in 2024 (LHS) and the generation
capacity of VVER reactors (in GW) (RHS) by Member State
100%
90%
80%
70%
60%
50%
40%
68%
62%
30%
42%
42%42%41%39%
20%
34%
29%
10%
24%
20%
20%
3%
0%
2,2
2,3
2,1
1,9
2,0
GW
1,0
VVER-1000
VVER-1000
VVER-440
VVER-440
VVER-440
Bulgaria
Czechia
Finland HungarySlovakia
Nuclear
Renewables
Fossil
Source: DG ENER based on Ember, Apis-project.eu and Euratom Supply Agency annual report 2023
The nuclear fuel cycle is the series of industrial processes that involve the production of
energy from uranium in nuclear power reactors. The front-end of the nuclear fuel cycle
involves i) extracting uranium ore through mining, ii) converting it to uranium hexafluoride
gas for enrichment (conversion to natural UF6), iii) increasing the concentration of the fissile
isotope U-235 (enrichment to enriched UF6), and iv) fabricating it into fuel pellets,
assembled into rods and fuel assemblies, ready for use in nuclear reactors.
23
Russia, largely through bundled contracts, supplies products and services to EU customers
across the whole front-end nuclear fuel cycle. The EU utilities then receive finished products,
either enriched uranium products or the fuel. The share of Russian supplies at each stage is as
follows (see Figure
).
-
Natural uranium: Around 23% (or 3,419 tonnes of Uranium (tU)) of natural uranium
imported to the EU originated directly from Russia in 2023. Effectively, however,
including indirect supplies via intermediaries in other countries
24
, this share increases
to over 26%. This positions Russia as the second largest supplier of natural uranium to
the EU, after Canada (33%). A preliminary analysis by the Euratom Supply Agency
The ‘back end’ of the fuel cycle includes the steps of temporary storage, reprocessing, and recycling before
the waste is disposed.
24
This primarily affects intermediaries in Kazakhstan.
23
12
VVER-440
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indicates that in 2024, uranium supplies from Niger and Russia saw a substantial
decrease, while supplies from Australia returned to 2020 levels, increasing by a factor
of over 3. Additionally, China appeared as a supplier for the first time.
-
Conversion services: In 2023, the EU relied on Russia for 27% (or 3,543 tU) of its
conversion services. Preliminary data indicates a decrease in Russia's share to 23% in
2024.
Enrichment services: Russia's share was 38% (or 4,647 tSW
25
) in 2023, a particularly
large share resulting from the fact that European companies increased their inventory
of enriched uranium in 2023 to secure supply in the face of a volatile international
context. Preliminary data indicates a decrease in Russia's share to 24% in 2024.
-
Figure 13: Russian supplies along the EU’s nuclear fuel cycle, 2023
100%
90%
80%
70%
45%
77%
55%
Other
29%
7%
60%
50%
40%
30%
EU
Russia
38%
20%
10%
0%
Uranium mining
Conversion
23%
27%
Enrichment
Source: DG ENER based on Euratom Supply Agency annual report 2023
Note: In 2024, based on preliminary data, the share of Russian supplies to meet EU demand decreased to 23% for
conversion services and 24% for enriched uranium.
-
In fuel fabrication, the dependency is most significant in the five Member States using
the VVER reactors which account for 23% of Finland's nuclear power capacity and
100% of that in Bulgaria, Czechia, Hungary and Slovakia.
Some Member States, in particular those with VVER reactors, also rely on Russia for critical
technology, spare parts and maintenance and other related services. However, transparency
about the nature of the parts and services sourced from Russia – and the extent to which
Member States depend on Russia for these parts and services – is limited. As part of their
national phase-out plans, Member States are therefore expected to gather systematic
information on all supplies from Russia and this will provide the basis to develop concrete
plans and actions to diversify away from Russia.
The EU dependency on Russia across the nuclear supply chain constitutes a serious risk for
the Union’s security of supply. In the five Member States operating VVER reactors, nuclear-
25
The separative work unit (SWU) is the common unit for enrichment and indicates the energy input relative to
the amount of uranium processed, the degree to which it is enriched and the level of depletion of the remainder.
13
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based generation contributes between 39% to 62% to the country’s electricity production. If
this generation capacity was not available because of disruptions in the supply of nuclear
material, the repercussions could be very serious as the non-nuclear capacity may not be
sufficient to compensate for the nuclear production, especially at times of high demand. Even
if generation from other sources and imports from neighbouring Member States could
compensate for the missing nuclear generation, the effects on prices could be significant. The
absence of nuclear generation would require calling into operation more expensive plants
which would set the wholesale price at a significantly higher level.
26
This in turn would have
knock-on effects on retail prices. It has been estimated that the peak in wholesale electricity
prices in 2022 was followed by an increase in retail prices of 46% of the increase in
wholesale prices on average, and the pass-through was as high as 135% in some Member
States.
27
The dependency on Russia in the nuclear sector jeopardises not only the security of electricity
supply but also nuclear safety and security, in particular in case of supply disruptions of
critical technology, spare parts and maintenance and other related services, with potential
economic, societal, health and environmental consequences, in turn leading to a serious risk
to the overall EU security and autonomy. Russia’s lack of commitment to nuclear safety and
security is demonstrated by Russian military activities around the Ukrainian nuclear facilities
since the start of the war in 2022. Russia’s military objectives appear to take precedence over
nuclear safety and security in cases such as the intrusion of Russian troops into the Chernobyl
exclusion zone in the beginning of the war as well as the occupation of the Zaporizhzhia
nuclear power plant in Ukraine (ZNPP). At the ZNPP, the competent nuclear safety regulator
no longer has the necessary access to ensure that applicable national and international nuclear
safety standards are being upheld. Attacks against nuclear installations such as the sustained
targeting of the Kharkiv Institute of Physics and Technology or targeting of nuclear power
plant infrastructure such as emergency power lines necessary for safe operation, violate all
the seven indispensable nuclear safety and security pillars outlined by the International
Atomic Energy Agency at the beginning of the conflict.
28,29
Moreover, in 2023, Russia
rescinded the ratification of the Comprehensive Nuclear Test Ban Treaty, further putting into
question its commitment to nuclear safety and non-proliferation.
More generally, Russian nuclear power plant building projects in the EU and beyond, such as
the ones constructed or operated by Rosatom, have embedded hybrid threat potential, where
spillovers to different domains such as intelligence, legal, economic, information, social,
infrastructure, political and military can be used to exert powerful leverage. Rosatom is part
of the Russian state’s foreign policy and any deal for nuclear power plant construction has
objectives aside from economic ones.
30
Zani, A., Blanco, M. P., Purvins, A., & L’Abbate, A. (2019, September). Impact of nuclear supply outage on
the European electricity system. In 2019 16th International Conference on the European Energy Market (EEM)
(pp. 1-5). IEEE.
27
European Commission, Quarterly Report on the Euro Area Volume 22, No 2 (2023).
28
https://www.iaea.org/sites/default/files/documents/nuclear-safety-security-and-safeguards-in-ukraine-feb-
2023.pdf
29
IAEA Director General Grossi’s Initiative to Travel to Ukraine | IAEA
30
Nuclear energy and the current security environment in the era of hybrid threats - Hybrid CoE - The European
Centre of Excellence for Countering Hybrid Threats
26
14
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Dependencies on Russia in the nuclear sector are technically complex covering natural,
converted and enriched uranium, nuclear fuel assemblies, spare parts and maintenance
services and medical radioisotopes. They fall within the purview of the Euratom Treaty, as
lex specialis, in addition to TFEU. This implies different structure for the assessment of
impacts and for the different legal bases of the legislative proposals foreseen under the
Roadmap for nuclear than those for oil and gas (exclusively under the TFEU for gas and oil
and under both Euratom and TFEU for nuclear). The legislative procedures required
according to the different legal bases will also differ. It is thus important to ensure a common
understanding among all stakeholders of the impact of these dependencies and the measures
necessary to end the nuclear supplies from Russia. A practical solution is therefore to
decouple the legislative proposals for the two workstreams, with oil and gas being tabled first
in mid-June 2025 and nuclear envisaged soon after at a later date. This will allow for the
definition of a clear path to the adoption through dedicated preparatory discussions with the
nuclear industry and the legislator. In view of this, the remaining part of this staff working
document will not discuss further the measures related to nuclear.
3.3. Oil
In June 2022, the EU adopted the sixth package of sanctions which included an import ban on
all Russian seaborne crude oil from December 2022 and petroleum products from February
2023.
As a result, the share of Russian crude oil dropped from 27% of the EU imports in 2022 to
3% in 2024.
31
The remaining imports come mostly via pipelines which have benefitted from
temporary exemptions from the EU sanctions regime. Three Member States were served by
Russia via pipeline: Czechia, Slovakia and Hungary. However, since April 2025 Czechia no
longer imports Russian oil. That was made possible thanks to the completion of the TAL-
PLUS project that expanded the capacity of Transalpine pipeline transporting oil from the
Italian terminal in Trieste to the refineries in Central-Eastern Europe (see Box 3 below with
more details on Czechia’s successful phase out of Russian crude oil).
Yet, for Slovakia and Hungary, Russian oil through the Druzhba pipeline through Ukraine
still represents over 80% of their total oil imports
32
with the remaining 20% imported via the
Adria pipeline through Croatia. The high dependency for those countries poses a risk for their
security of supply as Russia may unilaterally and abruptly cut or reduce the oil flow, as it did
with gas. This may have consequences also for Slovak and Hungarian downstream markets of
refined products. There is one oil refinery in Slovakia which works in close coordination
with another refinery in Hungary as both refineries are operated by MOL. The Slovak
refinery produces several petroleum products (e.g. diesel and gasoline) and accounts for
virtually all of Slovakia’s domestic demand. Similarly, the production of the Hungarian
refinery (diesel and gasoline) is essential to serve the domestic demand, covering more than
80% of Hungary’s consumption. As acknowledged by MOL, the company operating the two
refineries receiving Russian crude oil, its refining business is exposed to the risk of disruption
31
32
This share has further dropped in 2025 since Czechia stopped importing from Russia in April.
According to COMEXT information from 2024 and 2023.
15
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of the physical flow coming from Russia: "The
physical flow of the crude oil from Russia has
been periodically disrupted due to war damage on Ukrainian energy infrastructure”.
33
4. Measures on Russian gas supplies
The gas-related measures envisage a comprehensive set of actions to support and ultimately
achieve the complete phase out of Russian gas. These include:
-
a prohibition of gas imports based on new contracts concluded after [17 June 2025] -
by the end of 2025, and a ban of the remaining imports based on existing contracts by
the end of 2027;
a prohibition to provide services in EU LNG terminals to customers from the Russian
Federation as of 1 January 2026, with a transition phase of the prohibition for existing
LNG terminal services contracts until 31 December 2027 for services provided under
long-term contracts;
an obligation for Member States to have an active role in the phase out of their
Russian gas, direct or indirect, imports by preparing and adopting national
diversification plans with detailed measures and milestones; and
proposals to improve the transparency, monitoring and traceability of Russian gas
across the EU markets by (i) facilitating the exchange of information among relevant
national authorities in Member States and the Commission and (ii) enhancing
transparency on contracts for Russian gas.
-
-
-
This section is structured as follows: (i) it discusses the available alternatives to replace
Russian gas; (ii) it provides an overview of the status-quo of the development of the
infrastructure to receive and transport gas in the EU; and (iii) it assesses the impact of the
measures set out in the proposal from an economic and legal perspective.
4.1. Available alternatives to replace Russian gas
Since the beginning of the crisis, the EU has been increasingly reliant on LNG, which played
a fundamental role in replacing Russian pipeline gas imports. EU imports of LNG from non-
Russian countries went from 60 bcm in 2021 to more than 100 bcm/y in two years (2023).
LNG of non-Russian origins accounts now for not less than 30% of the EU imports, twice as
much as the pre-crisis level.
As of 2025, the LNG global supply is set to grow significantly - and at increasingly fast pace
- with 33 bcm of additional capacity in 2025, more than 50 bcm in 2026, nearly 70 bcm in
2027, and 50 bcm in 2028. This will increase the total LNG capacity by about 200 bcm by
2028, five times more than the EU imports of Russian gas.
34
Overall, between 2025 and
2030, close to 270 bcm/y of new LNG export capacity is expected to come online from
projects that have already been approved. This represents the largest capacity wave in any
33
34
MOL Group Integrated Annual report 2024.
IEA (January 2025) “Gas Market Report, Q1-2025”
16
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comparable period in the history of LNG markets.
35
While some of those projects are
unlikely to supply gas directly to Europe, they would free up supplies from other parts of the
world that can then serve the EU markets.
Figure 14: Cumulative LNG liquefaction capacity additions from post-FID projects, 2025-
2030
Source: International Energy Agency
36
Note: status on 15 May 2025
More supply from sources other than LNG will also become available in Central and South-
East Europe, a region traditionally dependent on Russian pipeline supplies. As of 2027 the
Neptun Deep offshore gas field in Romania is expected to produce 8 bcm/y of natural gas in
the first 10 years of its operation. Also, from 2026, the capacity of the Trans Adriatic Pipeline
will be expanded by 1.2 bcm allowing increased gas imports from Azerbaijan.
4.2.
Status of the EU infrastructure
Over the past years, the EU has diversified its energy supply sources and routes and
strengthened its security of supply. Thanks to the EU policies and financial support through
the Connecting Europe Facility (CEF), the European Energy Programme for Recovery
(EEPR), cohesion policy funds and other EU instruments, a number of key gas (and
electricity) infrastructure projects in Central and Eastern Europe have come online making
the EU energy system more resilient to disruption. Since 2014, the EU has disbursed nearly 8
billion EUR to interconnect and reinforce the energy infrastructure of EU countries, including
more than 1,6 billion EUR for gas Projects of Common Interest (PCIs) under CEF,
This figure excludes capacity additions from Russia’s Arctic LNG 2 project (27 bcm/y), Mozambique LNG
(18 bcm/y), and Qatar’s North Field West expansion (22 bcm/y) — all of which have been approved but are not
progressing toward normal commercial operation for various reasons.
36
See
Global LNG Capacity Tracker – Data Tools - IEA
35
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contributing to the security of supply, gas market integration and competitiveness of EU
energy markets.
4.2.1. LNG import capacity
Between 2022 and 2024 a record of twelve new LNG terminals and six expansion projects
were commissioned, adding 70 bcm of LNG import capacity to the EU, including the former
Project of Common Interest, Alexandroupolis LNG terminal in Greece (5,5 bcm/y). Before
this period, the EU supported the realisation of two PCI projects, namely the LNG terminals
in Świnoujście (Poland) and on the Krk island (Croatia)
37
. Additional capacities have been
deployed in Northern as well as in South-Eastern regions of Europe, giving closer access to
LNG to landlocked countries and ensuring a balanced geographical distribution of receiving
facilities across the EU, which is essential for the efficient pipeline transportation of gas to
the nearest consumption centres. The map below shows the location of the new regasification
plants deployed since 2022.
Figure 15: Location of new LNG regasification capacities in the EU since 2022
Source: DG ENER based on ENTSOG
Note: the map also shows the Krk terminal in Croatia which was commissioned before 2022 but whose capacity
was expanded in reaction to the crisis.
The EU’s total LNG import capacity now amounts to approximately 250 bcm/y, more than
twice the current LNG imports. The average utilisation of this capacity was ‘only’ 42% in
37
The LNG terminal in Swinoujscie, Poland had capacity of 5 bcm/y after completion in 2016. Expansion
project of the terminal was also a PCI project and allowed the ter
minal to increase its regasication capacity to 8,3 bcm/y. The FSRU terminal in Krk was inaugurated in 2021 and
had an initial capacity of 2,6 bcm/y. Its current regasification capacity has reached 3,5 bcm/y.
18
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2024. This suggests that the EU has plenty of spare capacity to accommodate for additional
LNG import to replace Russian supplies.
Figure 16: Regasification capacity utilised by country (%) in 2024
Source: Joint Research Centre based on ALSI-GIE
38
4.2.2. Cross-border interconnection capacity
The EU’s gas interconnection has also been substantially enhanced thanks to the completion
of key interconnectors as well as internal reinforcements of the transmission systems. Before
Russia’s invasion of Ukraine, critical (former) Projects of Common Interest were completed
in the EU, in particular in Central-Eastern and South-Eastern Europe, regions traditionally
dependent on Russian pipeline supplies. Table 2 provides a comprehensive overview of the
Projects of Common Interest in CEE and SEE regions completed so far and Figure 17 shows
where these projects were located.
38
JRC Gas SOS Dashboard
Microsoft Power BI
19
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Figure 17: Completed Gas Projects of Common Interest
Source: PCI-PMI Transparency Platform
Table 2:
Completed Projects of Common Interest in Central-Eastern and South-Eastern Europe
Project
The Slovakia – Hungary Gas Interconnection
Description
Onshore pipeline between Vel’ké Zlievce,
Balassagyarmat and Vecsés connected Slovakia
and Hungary, establishing the foundations for
gas transmission within the North-South gas
corridor between Central Eastern and South
Eastern Europe. The current capacity from
Hungary to Slovakia is 2,4 bcm/y with a pilot
firm capacity at the level of 3,5 bcm/y. Current
capacity from Slovakia to Hungary is 4 bcm/y.
These pipelines linked Azerbaijan's gas fields to
Europe, providing an alternative gas supply
route via Greece and Italy to reduce dependency
on Russian gas. The current capacity of the
Southern Gas Corridor towards the EU is 11
20
Southern Gas Corridor, including Trans
Anatolia Natural Gas Pipeline (TANAP) and
the Trans-Adriatic Pipeline (TAP)
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Phase 1 of BRUA corridor between Bulgaria,
Romania and Hungary
The Baltic Pipe
The North – South Gas Corridor in western
Poland
The North-South Gas Corridor in eastern
Poland
The Poland-Lithuania gas interconnector
Interconnection Estonia — Finland
(Balticconnector)
Enhancement of Estonia — Latvia
interconnection
The Enhancement of Latvia-Lithuania
interconnection
Internal Croatia’s evacuation pipelines from
the Krk terminal towards Hungary
bcm/y.
This project developed transmission capacity in
Romania from Podișor to Recas, enhancing
regional connectivity with new pipelines and
compressor stations at Podișor, Bibești, and
Jupa. The current capacity from Romania to
Hungary is 2,5 bcm/y.
This pipeline connected Norway's gas supplies
to Denmark and Poland, strengthening European
energy security through diversifying gas sources
in Central-Eastern Europe. The capacity of the
pipeline is 10 bcm/y.
This corridor enhanced gas transmission from
the Baltic Sea towards Slovakia and South-East
Europe, improving supply reliability and
flexibility within Poland and neighbouring
countries.
The majority of pipelines within this corridor
has been realised. As a result, the corridor
connected the LNG terminal in Swinoujscie and
the Baltic Pipe through central and southern
Poland with the infrastructure in Central-Eastern
Europe.
This project linked the gas networks of Poland
and Lithuania, facilitating bi-directional gas
flows, enhancing energy security in the Baltic
region and enabling imports from the Klaipeda
terminal towards Central-Eastern Europe. The
capacity from Poland to Lithuania is 2,3 bcm/y
and 1,8 bcm/y from Lithuania to Poland.
This subsea pipeline connected the natural gas
grids of Estonia and Finland, providing
Finland’s supply diversification and access to
the Incukalns underground gas storage facility
in Latvia. Capacity from Estonia to Finland is
2,2 bcm/y and from Finland to Estonia is 2,5
bcm/y.
The project allowed bi-directional gas flow
between Estonian and Latvian gas transmission
systems and enabled bi-directional gas transport
between Finnish and Baltic gas systems,
together with the completion of Balticconnector
offshore pipeline. The current bi-directional
capacity of the interconnection is 3,6 bcm/y.
This project improved the gas interconnectivity
between Latvia and Lithuania, facilitating better
integration and energy resilience in the Baltic
states. Current capacity from Lithuania to Latvia
is 2,8 bcm/y and from Latvia to Lithuania 2,6
bcm/y.
Beyond the completion of the Krk terminal in
Croatia, these pipelines enabled transportation
of regasified LNG from the terminal in Croatia
towards Hungary, expanding regional gas
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The Poland-Slovakia gas interconnector
Gas interconnector Greece-Bulgaria (IGB)
Rehabilitation, modernisation and expansion
of the Bulgarian transmission system
Interconnector Bulgaria-Serbia
The Trans-Balkan reverse flow project
supply routes. The current capacity from Croatia
to Hungary is 1,6 bcm/y and from Hungary to
Croatia 2,4 bcm/y.
This pipeline connected Polish and Slovak gas
networks, providing alternative supply routes
and bolstering energy security in Slovakia and
entire Central Europe. Current capacity from
Poland to Slovakia is 4,5 bcm/y and from
Slovakia to Poland 5,5 bcm/y.
This pipeline linked Greek and Bulgarian gas
grids, enabling access of Central-Eastern and
South-Eastern Europe to diverse sources such as
Greek LNG terminals and the Southern Gas
Corridor. Current capacity of IGB is 3,3 bcm/y
from Greece to Bulgaria.
This project upgraded and expanded Bulgaria's
gas transmission system, enhancing capacity
and enabling large-scale transportation of
natural gas from Greece and Southern Gas
Corridor towards Central-Eastern and South-
Eastern Europe.
This pipeline connected gas networks of
Bulgaria and Serbia, enabling Serbia to
diversify away from Russia and enhancing
security of supply in the Western Balkans
region. The capacity from Bulgaria to Serbia is
1,6 bcm/y.
This non-PCI initiative carried out under the
CESEC High-Level Group allowed reverse gas
flows from Greece to Bulgaria, Romania,
Moldova and Ukraine through the Trans-Balkan
pipeline, enhancing connectivity and supply
diversification for Central-Eastern and South-
Eastern Europe.
39
The gas infrastructure in the EU is sufficiently developed, well-interconnected and flexible,
to enable Member States
40
to access LNG and pipeline imports from non-Russian sources.
Nonetheless, additional infrastructure projects are currently under completion to remove
remaining bottlenecks, enhance the diversification capability and further strengthen the
security of supply in Central and South-East Europe.
In the preparatory phase before adopting the REPowerEU Plan in 2022, the Commission
analysed how to tackle the existing dependency on Russian gas supply and address the
remaining infrastructure bottlenecks. The Commission focused on identifying projects that
would address the infrastructure needs, provide benefits to multiple Member States and that
could be accomplished within the REPowerEU timeline.
39
40
Non-PCI priority project completed in the framework of the CESEC High-Level Group
except Cyprus and Malta.
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Upon the Commission’s request, ENTSOG analysed, considering different demand scenarios
and assuming various levels of infrastructure development,
41
the status of the EU gas
network, and assessed whether infrastructure bottlenecks exist and the extent to which such
bottlenecks would pose a risk for the EU security of supply in case Russian gas flows to the
EU were to stop.
This assessment was subsequently discussed with Member States in the High-level Groups
42
and led to the identification of a limited number of gas infrastructure projects, mainly in
Central and South-Eastern Europe, which would help Europe meet the REPowerEU objective
of full independence from the Russian gas. These projects are included in Annex III to the
REPowerEU Plan. Some of the REPowerEU projects have already been completed and
others are at an advanced stage of development with a completion dates by 2026.
To mobilise financing for the objectives of REPowerEU, Member States have been allowed
to add REPowerEU chapters to their Recovery and Resilience Plans, including additional
reforms and investments needed. The Commission decided to financially support the projects
listed in Table 3 below through the Recovery and Resilience Facility (RRF). In addition, the
Commission supported three underground gas storage facilities in South-East Europe under
the Connecting Europe Facility to enhance the storage capacity and flexibility, one in
Bulgaria (Chiren) and two in Romania (Bilciuresti and Depomures).
Table 3: REPowerEU projects financially supported by the EU
Project
Expansion of the
Krk FSRU terminal in Croatia
Technical details
Current regasification capacity of the Krk
terminal is 3,5 bcm/y. After the completion of the
supported project, the capacity will increase to
6,1 bcm/y.
The commissioning of the project is
planned in 2026.
Transmission infrastructure reinforcements in
Croatia to substantially increase
cross-border
capacities of Croatia with Slovenia and
Hungary,
widening import options for Central-
Eastern and South-Eastern Member States.
Current technical capacity from Croatia to
Slovenia is 0,2 bcm/y. The supported project will
increase it to 1,5 bcm/y. Existing interconnection
between Croatia and Hungary has 1,6 bcm/y. The
supported project will lead to
capacity increase
to up to 3,5 bcm/y by 2026.
41
42
REPowerEU Plan, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022DC0230
Four High-Level Groups facilitate close cooperation on energy infrastructure development between EU and
partner countries in priority regions,
https://energy.ec.europa.eu/topics/infrastructure/high-level-groups_en
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The
Adriatica Line and Poggio Renatico
The supported projects will increase transport
compressor station
to remove existing bottleneck capacity along the south-north route from the
entry points located in southern Italy from 126
within the Italian gas network
million to around
131 million Sm3/g,
and to
increase the transport capacity from the points
interconnected with the LNG terminals in the
North Adriatic (Ravenna) from
31 to 40 million
Sm3/g,
with an increase of around 9 million
Sm3/g. Commissioning of the project is
expected
by 2026.
Increase in the
capacity between Italy and
Austria,
facilitating imports from new FSRU
terminals in Italy, Azerbaijan, Northern Africa and
regional cross-border flows across entire Central-
Eastern Europe
Current capacity from Italy to Austria is 8,2
bcm/y. Once the supported projects are
completed by 2026,
the capacity will reach up to
14,6 bcm/y.
The supported investment within the FSRU
terminal in Gdansk entails constructing the 250-
km onshore pipeline connecting the terminal with
the Polish transmission network. The pipeline
project commissioning is planned
in 2026.
The
FSRU Gdansk terminal will have
6,1 bcm/y
of
regasification capacity.
The
onshore section of the FSRU terminal
project in Gdansk,
enhancing security of supply
of the Baltic region and further facilitating North-
South gas flows towards Central-Eastern and
South-Eastern EU Member States.
The completion of these projects will address the infrastructure bottlenecks in Central-
Eastern and South-Eastern Europe identified by ENTSOG in the REPowerEU Plan and, as a
result, Member States in the region will be able to fully utilise eleven transmission corridors
to carry gas from the entry points in the EU grid system (either LNG terminals or pipeline) to
their domestic markets.
43
These are the eleven corridors
44
:
1.
Baltic Pipe between Norway-Denmark-Poland-Slovakia via Faxe and Vyrava
interconnection points (IPs)
45
2.
Lithuania-Poland-Slovakia via Santaka and Vyrava interconnection points
46
3.
Italy-Austria-Slovakia via Tarvisio/Arnoldstein and Baumgarten interconnection
points
47
43
ENTSOG system capacity map and transparency platform, https://www.entsog.eu/maps
and
https://transparency.entsog.eu/#/map
44
All figures are based on official data available in the ENTSOG datasets provided in GWh/d. All values
expressed in bcm/y are indicative and are presented as approximate figures due to unit conversions and
rounding, to ease interpretation
45
The Baltic Pipe has a capacity of 321,6 GWh/d (10 bcm/y). The Vyrava interconnection Point (IP) has a
capacity of 173,9 GWh/d (5,4 bcm/y) from Slovakia to Poland and 144,5 GWh/d (4,5 bcm/y) from Poland to
Slovakia.
46
The Santaka IP has a capacity of 73,3 GWh/d (2,3 bcm/y) from Poland to Lithuania and 58,1 GWh/d (1,8
bcm/y) from Lithuania to Poland. The Vyrava interconnection Point (IP) has a capacity of 173,9 GWh/d (5,5
bcm/y) from Slovakia to Poland and 144,5 GWh/d (4,5 bcm/y) from Poland to Slovakia.
47
The Tarvisio/Arnoldstein IP has a capacity of 1.192,4 GWh/d (37,4 bcm/y) from Austria to Italy and 263,8
GWh/d (8,2 bcm/y) from Italy to Austria. The Baumgarten IP has a capacity of 246,5 GWh/d (7,7 bcm/y) from
Austria to Slovakia and 1.570,4 GWh/d (49,2 bcm/y) from Slovakia to Austria. The capacity of the
24
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4.
Italy-Austria-Hungary
5.
via
Tarvisio/Arnoldstein
and
Mosonmagyaróvár
6.
7.
8.
9.
10.
11.
interconnection points
48
Croatia-Hungary via Dravaszerdahely interconnection point
49
Greece-Bulgaria-Romania-Hungary via Kulata/Sidirokastron, Stara Zagora (IGB),
Negru Voda/Kardam, Csanadpalota interconnection points
50
Germany-Czechia-Slovakia via VIP Brandov and Lanžhot interconnection points
51
Germany-Austria-Slovakia via VIP Oberkappel and Baumgarten interconnection
points
52
Germany-Austria-Hungary via VIP Oberkappel and Mosonmagyaróvár
interconnection points
53
Germany-Poland-Slovakia via Mallnow, GCP GAZ-SYSTEM/ONTRAS and Vyrava
interconnection points
54
Trans-Balkan pipeline between Greece, Bulgaria, Romania, Moldova, Ukraine,
Hungary and Slovakia via Kulata/Sidirokastron/, Stara Zagora (IGB), Negru
Voda/Kardam, Isaccea/Orlivka, Kaushany, Grebenyky and Uzhgorod/Velke
Kapusany, Budince, VIP BEREG interconnection points
55
Tarvisio/Arnoldstein IP will be increased to 14,6 bcm/y from Italy to Austria after completion of the
REPowerEU projects in Italy in 2026.
48
The Tarvisio/Arnoldstein IP has a capacity of 1.192,4 GWh/d (37,4 bcm/y) from Austria to Italy and 263,8
GWh/d (8,2 bcm/y) from Italy to Austria. The Mosonmagyaróvár IP has the capacity of 153,1 GWh/d (4,8
bcm/y) from Austria to Hungary. The capacity of the Tarvisio/Arnoldstein IP will be increased to 14,6 bcm/y
from Italy to Austria after completion of the REPowerEU projects in Italy in 2026.
49
The Dravaszerdahely IP has a capacity of 76,3 GWh/d (2,4 bcm/y) from Hungary to Croatia and 50,5 GWh/d
(1,6 bcm/y) from Croatia to Hungary. The capacity of this IP will be increased to 3,5 bcm/y from Croatia to
Hungary after the completion of the REPowerEU projects in Croatia by 2026.
50
The Kulata/Sidirokastron IP has a capacity of 120,2 GWh/d (3,8 bcm/y) from Bulgaria to Greece and 66,6
GWh/d (2 bcm/y) from Greece to Bulgaria. The Stara Zagora IP (IGB) has a capacity of 107,0 GWh/d (3,3
bcm/y) from Greece to Bulgaria. The Negru Voda/Kardam IP has a capacity of 157,7 GWh/d (4,9 bcm/y) from
Bulgaria to Romania and 189,5 GWh/d (5,9 bcm/y) from Romania to Bulgaria. The Csanadpalota IP has a
capacity of 78,8 GWh/d (2,4 bcm/y) from Romania to Hungary and 78,0 GWh/d (2,4 bcm/y) from Hungary to
Romania. The Kulata/Sidirokastron IP is expected to be increased to 3,2 bcm/y by the end of 2025. The Negru
Voda/Kardam IP is expected to be increased up to 9,2 bcm/y by mid-2026.
51
The VIP Brandov has a capacity of 268,8 GWh/d (8,4 bcm/y) from Germany to Czechia and 198,3 GWh/d
(6,2 bcm/y) from Czechia to Germany. The Lanžhot IP has a capacity of 1399,0 GWh/d (43,9 bcm/y) from
Czechia to Slovakia and 384,8 GWh/d (12 bcm/y) from Slovakia to Czechia. The VIP Brandov will be increased
up to 18,8 bcm/y from Germany to Czechia by the end of 2026.
52
The VIP Oberkappel has a capacity of 214,5 GWh/d (6,7 bcm/y) from Germany to Austria and 113,3 GWh/d
(3,5 bcm/y) from Austria to Germany. The Baumgarten IP has a capacity of 246,5 GWh/d (7,7 bcm/y) from
Austria to Slovakia and 1.570,4 GWh/d (49,2 bcm/y) from Slovakia to Austria. The VIP Oberkeppel will be
increased up to 9,2 bcm/y in the first half of 2027.
53
The VIP Oberkappel has a capacity of 214,5 GWh/d (6,7 bcm/y) from Germany to Austria and 113,3 GWh/d
(3,5 bcm/y) from Austria to Germany. The Mosonmagyaróvár IP has the capacity of 153,1 GWh/d (4,8 bcm/y)
from Austria to Hungary. The VIP Oberkappel will be increased up to 9,2 bcm/y in the first half of 2027.
54
Mallnow IP has a capacity of 259,2 GWh/d (8,1 bcm/y) from Germany to Poland. GCP GAZ-
SYSTEM/ONTRAS IP has a capacity of 48,7 GWh/d (1,5 bcm/y) from Germany to Poland. The Vyrava
interconnection Point has a capacity of 173,9 GWh/d (5,4 bcm/y) from Slovakia to Poland and 144,5 GWh/d
(4,5 bcm/y) from Poland to Slovakia.
55
The Kulata/Sidirokastron IP has a capacity of 120,2 GWh/d (3,8 bcm/y) from Bulgaria to Greece and 66,6
GWh/d (2 bcm/y) from Greece to Bulgaria. The Stara Zagora IP (IGB) has a capacity of 107,0 GWh/d (3,3
bcm/y) from Greece to Bulgaria. The Negru Voda/Kardam IP has a capacity of 157,7 GWh/d (4,9 bcm/y) from
Bulgaria to Romania and 189,5 GWh/d (5,9 bcm/y) from Romania to Bulgaria. The Isaccea/Orlivka IP has a
capacity of 122,0 GWh/d (3,8 bcm/y) from Romania to Ukraine and 201,9 GWh/d (6,3 bcm/y from Ukraine to
25
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Figure 18: Map of Central-Eastern and South-Eastern European gas infrastructure
56
Source: Gas Infrastructure Europe
Romania. The Kaushany IP has a capacity of 348.9 GWh/d (10,9 bcm/y) from Moldova to Ukraine and 133,7
GWh/d (4,1 bcm/y) from Ukraine to Moldova. The Grebenyky IP has a capacity of 81,4 GWh/d (2,5 bcm/y)
from Moldova to Ukraine and 348,9 GWh/d (10,9 bcm/y) from Ukraine to Moldova. The Uzhgorod/Velke
Kapusany IP has a capacity of 1.861,6 GWh/d (58,4 bcm/y). The Budince IP has a capacity of 202,2 GWh/d (6,3
bcm/y). The VIP Bereg has a capacity of 517,5 GWh/d (16,2 bcm/y). The Kulata/Sidirokastron IP is expected to
be increased to 3,2 bcm/y by the end of 2025. The Grebenyky IP is expected to increase up to 4,1 bcm/y. The
Negru Voda/Kardam IP is expected to be increased up to 9,2 bcm/y by mid-2026 and lead to simultaneous
increase of Isaccea/Orlivka, Kaushany and Grebeny IPs up to 7,3 bcm/y in the direction of Ukraine/Central-East
Europe.
56
Europe-wide System Capacity Maps,
https://www.entsog.eu/maps
and
https://www.gie.eu/publications/maps/
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The possibility to access and efficiently use the EU gas network, hence allowing the use of
different supply corridors, is ensured by a robust regulatory framework. It has delivered a
mature and well-integrated EU gas system, with low levels of congestion at cross-border
points
57
. The rules governing the access to cross-border capacity provide for the predictable
and non-discriminatory allocation of available capacity at interconnection points to all
network users
58
. Dedicated remedies are also provided in EU legislation to tackle and prevent
the occurrence of contractual congestion, or the hoarding of infrastructure capacity in
transmission or other critical system points, such as LNG terminals or underground storage
facilities.
59
Together, these rules guarantee an agile and secure access to cross-border
infrastructure capacity, an essential prerequisite for ensuring a successful diversification from
Russian gas supplies.
Tariffs applicable to the use of gas transmission infrastructure also play an important role in
the selection and economic viability of new supply routes. EU rules cater for transparent and
cost-reflective transmission tariffs by establishing detailed requirements for the structure of
those tariffs.
60
While transparency and fair transmission pricing encourages competition
between gas supply routes, it also ensures informed utilisation of the infrastructure by
providing network users with specific and predictable cost-signals. The applicable rules also
provide for significant flexibility in establishing tariffs or the underling methodologies.
61
It
further allows for significant tariff discounts for LNG and storage facilities, acknowledging
the general contribution to system flexibility and security of supply of such infrastructure
62
.
Box 1: Impactful regional cooperation: the CESEC High-Level Group
The Commission is steering joint regional efforts on the infrastructure and market integration
of Central-Eastern and South-Eastern European countries through the CESEC High-Level
Group, a unique regional cooperation that involves 9 EU Member States and 8 Energy
Community Contracting Parties.
The overarching objectives of the CESEC High-Level Group concerning natural gas are
twofold. First, CESEC monitors and accelerates the implementation of the REPowerEU gas
infrastructure priority projects indicated in Table 2. Second, as agreed by the CESEC
Ministers in 2024, the High-Level Group aims at optimising the use of existing infrastructure,
which in some Member States, has been significantly underutilised. To serve this objective,
CESEC launched two priority workstreams: one on gas quality harmonisation and the other
57
2024 Market Monitoring Report:
Infrastructure enhancement (e.g., new LNG terminals) and lower gas
demand in Q3 were reflected in easing of congestion at interconnectors between West and Central Europe.
58
As established in Commission Regulation (EU) 2017/459 of 16 March 2017 establishing a network code on
capacity allocation mechanisms in gas transmission systems and repealing Regulation (EU) No 984/2013
C/2017/1660, OJ L 72, 17.3.2017, p. 1–28.
59
Annex I point 2. of Regulation (EU) 2024/1789, establishing principles of capacity-allocation mechanisms
and congestion- management procedures concerning transmission system operators and their application in the
event of contractual congestion (so-called Congestion management procedure guidelines).
60
See Commission Regulation (EU) 2017/460 of 16 March 2017 establishing a network code on harmonised
transmission tariff structures for gas, C/2017/1657, OJ L 72, 17.3.2017.
61
By allowing for example national regulatory authorities to correct the reference price methodology of the
applicable transmission tariff either via benchmarking, equalisation or rescaling adjustments, as envisaged by
article 6 of Regulation (EU) 2017/460.
62
See Article 17 (3) of Regulation (EU) 2024/1789.
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on addressing regulatory and market barriers along the Trans-Balkan Pipeline (TBP).
TBP is composed of up to three pipelines, of which one (T1) is capable to transport gas from
Southern to Central-Eastern Member States and can therefore be a viable route to deliver
LNG and Azeri gas landed in Greece towards Bulgaria, Romania, Moldova, Ukraine and
Central-Eastern Europe. The pipeline can carry significant volume of gas and can therefore
play an important role in the region’s diversification effort, even more as from 2027, when
the Neptun Deep gas field in Romania is expected to come onstream (8 bcm/y capacity in the
first ten years of operation) providing another important source of diversification for the
Member States in the region.
Figure 19: the Trans-Balkan pipeline
Source: Gas Infrastructure Europe
Despite its potential, regulatory and market practices currently pose barriers to the utilisation
and commercial attractiveness of the TBP. Current issues include i) lack of firm capacity in a
number of interconnection points along the route, e.g. Isaccea/Orlovka (RO-UA) or
Grebenyky (MD-UA) IPs, ii) non-aligned gas quality requirements in reverse-flow in existing
interconnection agreements between TSOs, and iii) regulatory barriers to entry and operate in
gas markets along the corridor.
The CESEC High-Level Group is working to address these barriers, and significant progress
has already been achieved, for example in relation to the gas quality harmonisation where
several TSOs in the region have jointly signed a Memorandum of Understanding for
achieving a common solution by October 2025. In parallel, CESEC is actively engaging with
all stakeholders in the region with the aim to support a common resolution of the identified
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regulatory barriers.
The successful completion of the ongoing investments in Greece, Bulgaria and Ukraine by
2026, along with the removal of the existing regulatory barriers, will enable the Trans-Balkan
pipeline to transport up to 295 GWh/d (9,2 bcm/y) from Bulgaria to Romania and 232 GWh/d
(7,3 bcm/y) of gas from Romania to Ukraine towards Central-Eastern Member States. This
will benefit the gas markets in the region and will support the EU diversification efforts.
The existing infrastructure also ensures the security of Ukraine’s and Moldova’s supply in
case of need. Until recently, Ukraine was able to meet nearly its entire gas demand through
domestic production, totalling 18,7 bcm/y. However, following artillery and drone attacks by
Russia in Winter 2024/2025, certain production facilities in Ukraine were destroyed,
increasing the need for imports from the EU. Imports from European markets via
interconnections with Hungary, Poland and Slovakia proved it sufficient to compensate for
the lower domestic production.
Moldova has not imported Russian gas since the 2022 energy crisis. Its interconnection
capacity with neighbouring countries, especially Romania and Ukraine has allowed Moldova
to cover all its’s needs from EU gas markets
63
. This diversification was enabled by the
completion of the Ungheni-Chişinău pipeline in 2020, establishing a direct connection with
Romania. The work to improve the use of Trans-Balkan pipeline (discussed above) will
provide additional supply security to Moldova and Ukraine, including strengthening the
transit role of these countries after the full unblocking of the Trans-Balkan pipeline.
4.3. Assessment of the legislative proposals
4.3.1. The gas import ban
No risk for security of supply
in the EU arises if the phase out of Russian gas is planned,
well-prepared in advance and gradually achieved as envisaged by the proposed measures
Thanks to the abundant import capacity, and the well-connected and flexible gas
infrastructure (see Section 4.2), the EU is already able to meet its gas demand as well as its
storage filling targets during the injection season, even without Russian gas supply. This is
confirmed by “ENTSOG Summer Supply Outlook 2025”
64
. The ENTSOG report explores
several supply and demand scenarios and a number of storage level sensitivities, and it
concludes that “in
the case of a full disruption of Russian pipeline supplies, storage facilities
are sufficient to meet demand and achieve an average inventory target level of 35% across
the EU”,
which is considered by ENTSOG a safe level at the end of the winter. This result is
valid both in a scenario where the EU demand is comparable to current levels, and in a
scenario that assumes a 5% higher demand as forecast by the EU gas transmission system
operators.
In January 2025 Gazprom cut off supplies to Moldova’s break-away Transnistrian region, where electricity
was produced with Russian gas. In response to the ensuing energy crisis, the Union intervened with emergency
support of EUR 30m of gas supplies to both banks of the Nistru river, followed by a EUR 250 million
comprehensive package for energy independence and resilience of Moldova in February 2025.
64
SO0067-25_Report_Summer Supply Outlook 2025.pdf
63
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Furthermore, in the 2024 edition of the
Union-wide security of supply simulation
65
report
produced by ENTSOG in consultation with the Gas Coordination Group, the modelling of the
EU gas system shows that the European gas system is resilient even in extreme scenarios. In
the reference scenario without Russian gas imports and with exceptionally high demand and
low storage levels at the beginning of the winter, the European gas system is robust enough to
satisfy the demand and keep an adequate storage level at the end of the winter. The scenario
assumes that the post-crisis restructuration and efficiency gains in gas demand remains stable,
which is in line with observations of the last two years. Only in case of a combination of
severe peak demand conditions and infrastructure disruption, the system would be locally
tested to its limits. This demonstrates the high level of resilience of the European gas
infrastructure. The report concludes that ”the
simulation results show that short-term high
demand events (typically expected to occur late in winter) can be managed through efficient
withdrawals from UGS and LNG tanks […].”
In some very limited cases
66
ENTSOG noted
that “infrastructure
limitations can prevent a few Member States from fully efficient
cooperation”.
However, in its simulations ENTSOG took into account the existing European
gas infrastructure and ‘only’ projects to be commissioned before January 2026. It did not
consider additional projects and improvements that will be finalised later such as, for
instance, the ongoing work to maximise the utilisation of the Trans-Balkan pipeline (see Box
1 above), REPowerEU projects in Croatia, Italy, Poland as well as market-driven
infrastructure investments in Greece, Bulgaria, Austria and Germany. With the completion of
these projects, the EU gas network will face even less constraints than simulated by
ENTSOG, this will further improve Member States’ access to alternative routes to import gas,
especially in the Central-Eastern and South-Eastern European region, thereby further
enhancing the EU security of supply.
Figure 20: Average EU storage level in case of Russian supply disruption for different
demand scenarios
65
66
Security of Supply Simulation | ENTSOG
These very few cases might only emerge under the hypothesis of one day (peak day) of exceptionally high
demand, “occurring
with a statistical probability of once in 20 years”.
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Source: ENTSOG Summer Supply Outlook 2025 and European Commission
The measures envisaged in the proposal are also
unlikely to cause adverse effects on gas
prices
for the reasons set out below.
First, the available gas supply is set to grow significantly in the coming years.
Compared to pre-crisis, LNG plays a more important role in the EU gas mix (40% of the EU
imports) and, as a result, the EU gas prices are more exposed to the dynamics of LNG
markets. The LNG market is global, and the additional demand coming from the EU since the
start of the crisis has tightened the LNG global market causing higher prices and larger
volatility than pre-crisis. However, the market situation is on the verge of a structural change.
As shown above, a large wave of new liquefaction capacity is set to come online mainly in
the US and Qatar. By 2027 the LNG additional export available globally is expected to be of
160-170 bcm per year, almost five times more than the EU imports of Russian gas. Additional
capacities will also come online in Asia, Australia and Africa, and in neighbouring Algeria
and Egypt, also in the framework of the upcoming New Pact for the Mediterranean. In its
‘World
Energy Outlook 2024’,
the International Energy Agency considered alternative
projections for the LNG demand evolution and in all scenarios the new liquefaction capacity
is expected to largely outweigh any potential increase in demand. This will lead to a surplus
of LNG of at least 130 bcm by 2030 (see Figure 21) which eventually is set to ‘depress
international gas prices’.
The abundance of LNG will allow the EU to replace Russian gas
without causing any tension in the market, and thus with no material price consequences.
This view is largely supported by market analysts. For example, the Institute for Energy
Economics and Financial Analysis in its Global LNG Outlook 2024-2028 noted that
“Lackluster
demand growth combined with a massive wave of new export capacity is poised
to send global liquefied natural gas (LNG) markets into oversupply within two years. These
two trends are developing even faster than anticipated”.
67
Similarly, S&P Global Commodity
Insights argues that “LNG
supply entering the global market from 2026 is expected to exceed
non-European demand growth and lower prices”
68
and it predicts prices to fall rapidly as of
2026 with TTF prices expected to be
“average €15.0/MWh ($5.0/MMBtu) in 2030 (in real
2024 terms)”.
Along a similar line, Bloomberg indicated that: “the
global LNG market is on
track to see more supply than demand from 2027 onwards. It is poised to become increasingly
oversupplied by the end of this decade.”
69
67
68
Institute for Energy Economics and Financial Analysis:
Global LNG Outlook 2024-2028 (April 2024).
European Gas Long-Term Forecast Quarterly Update, March 2025
69
Global LNG Market Outlook 2030: Focus on Supply Risks | Insights | Bloomberg Professional Services
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Figure 21: projected liquefaction capacity vs projected demand worldwide
Source: IEA – World Energy Outlook 2024
Note: STEPS, APS and NZE reflect demand projections under different scenarios
Member States are well equipped to receive more LNG supplies from global partners. The
EU has a total regasification capacity of about 250 bcm (see above), of which more than half
is not yet utilised. The spare capacity is three times more than the existing gas imports from
Russia.
In addition to LNG, more supply from other sources will become available in the coming
years in Central and South-East Europe, a region traditionally dependent on Russian pipeline
supplies. In particular, the Neptun Deep offshore gas field in Romania (from 2027) and the
additional capacity to import from Azerbaijan via the Trans Adriatic Pipeline will make
available almost 10 bcm of additional gas.
Second, the EU demand for gas is on a steady downward path. Since 2021, the EU gas
consumption has dropped by 80 bcm/y and it is now down by 17% on average, compared to
pre-crisis.
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Figure 22: Natural gas demand reduction, Aug 2022 - Feb 2025
Source: DG ENER based on Eurostat (nrg_cb_gasm)
The full implementation of the energy transition and the recent Action Plan for Affordable
Energy are expected to further boost the decarbonisation of the EU energy system, leading to
replace up to 100 bcm of gas by 2030, or a further reduction in gas demand by 40-50 bcm by
2027.
70
This will contribute to alleviate the market tightness. It also shows how in reality only
a small part of the Russian imports would need to be replaced with alterative suppliers as the
projected reduction in consumption by 2027 is larger than the current import from Russia.
Third, as demonstrated in the previous section, the gas infrastructure in the EU is sufficiently
developed and flexible to accommodate for alternative routes to bring gas to the EU,
including for the Central and South-Eastern region.
Finally, in 2024 about 60% (approx. 20 bcm) of Russian supplies to the EU were LNG. LNG
is a global market where prices are determined by the interplay between demand and supply
globally and prices can only change when the balance between demand and supply does. The
phase-out of Russian LNG would likely lead to trades shifting around with Russia redirecting
its export to other regions (e.g. Asia) and Europe compensating with more imports from the
trusted partners. However, the LNG global supply would remain largely unaltered and so
would the prices.
In view of the expected timeline for the deployment of new liquefaction capacity and
domestic production, the Commission proposes a stepwise approach to phase out Russian
gas, starting with new contracts, followed by short term supplies. The reason is two-fold:
a) Short term (with duration of less than 1 year) purchases account for a minority of the
Russian imports (approximately one third, or 10-15 bcm/y) and large part of it is LNG
whose phase-out is unlikely to cause any material change in the global balance; this
will leave the more substantial part of the phase-out to a later stage (purchases under
70
The estimates are based on the Commission's long-term projections, adjusted for the recent developments in
gas demand. The projections reflect the information and expectations currently available and as such they are
subject to uncertainties related to unforeseeable developments of, for example, energy prices, geopolitical
situation and technological advancements in clean technologies.
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long-term contracts) when the benefits of the larger LNG supply globally
71
and the
lower demand in the EU will have been more extensively materialised.
b) The delineation between spot and short-term contracts and long-term contracts
envisaged in the proposal is intended to reflect the different volumes at stake and the
resulting differences when it comes to finding alternative suppliers.
As the global balance improves (+150-160 bcm/y of new liquefaction capacity by 2027),
more domestic production becomes available in the EU (Neptun Deep field, +8 bcm from
2027), and gas EU consumption continues declining (- 40-50 bcm by 2027), the EU can
safely complete the phase out of the remaining Russian gas currently under long-term
contracts (20-25 bcm/y), with limited risks for prices. A longer lead-time would also enable
European buyers to terminate existing contracts that include an obligation to deliver gas to
the EU and, if needed, to sign new contracts with alternative suppliers.
72
71
The replacement of Russian pipeline supply may increase the EU demand for LNG but this is unlikely to
cause any material change in the LNG global balance: (i) most of Russian pipeline imports come under long-
term contracts for which the proposal envisages a later deadline (2027) when 150-160 bcm of new liquefaction
capacity will have already come onstream, (ii) Russian pipeline supply to the EU is about 15 bcm/y and this
represents a very small share (approx. 2%) of the total liquefaction capacity available by 2027.
72
According to ACER’s price data collected for the purpose of calculating the LNG price assessment and
benchmarks (https://www.acer.europa.eu/gas/lng-price-assessment), Russian LNG prices, while competitive, are
not necessarily the cheapest ones. For example, Russian long-term contracts which are typically more closely
indexed to crude oil, remained competitive throughout 2023 and 2024 but other contracts from other origins
(and using other indexations) proved to be even more cost-effective.
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Box 2: The end of the Russian flow through Ukraine
In December 2019, Gazprom and Naftogaz Ukrainy signed a long-term agreement from
January 2020 to December 2024 to enable the transit on the Ukraine’s pipeline system of
Russian gas directed to the EU markets. Following Russia’s invasion of Ukraine, the gas flow
via this route has considerably decreased. However, in 2024 there was still about 15 bcm of
Russian gas transiting through Ukraine.
To prepare for the end of transit agreement, the European Commission worked closely with
Member States to ensure a smooth transition, by helping anticipate their diversification needs,
and prevent any impact on security of supply and markets. Through a dedicated group, the
Commission and Member States conducted a joint assessment of the situation and
diversification possibilities. The group met regularly to evaluate the availability of import and
transit capacities, volumes of non-Russian origin, and the potential impact on prices and
security of supply. The results were presented to the Energy Council, where Ministers
provided additional guidance and requests, further contributing to a coordinated preparation
at the EU and regional levels.
The joint assessment revealed that the European gas system had sufficient infrastructure
capacity to cope with the end of the gas volume coming through Ukraine. Thanks to recent
developments in LNG import capacities and interconnection capacities, the EU gas system
was already well-integrated, resilient, and flexible, to ensure that all Member States had
access to LNG and pipeline imports from alternative routes. The Commission also organized
a comprehensive crisis simulation exercise to test the resilience of the EU's security of
supply. The exercise confirmed that the EU was well-prepared for the end of the transit
agreement via Ukraine. Communication with market participants throughout the process was
another important element of the preparation work to encourage diversification and limit the
risk of last-minute reactions that could trigger large price increases.
On 1 January 2025, following the expiry of the transit agreement, Russian flows to the EU
transiting via Ukraine stopped. This resulted in a reshuffling of the flow patterns in the
Central-Eastern region of Europe but, as confirmed by Member States potentially affected in
the meeting of the dedicated group that took place on 2 January 2025, no concerns for the
security of gas supply to the Region arose as a result of the end of the transit.
The effects on prices were also limited. No significant and lasting price increase materialised
after the halt of the flow through Ukraine. Gas prices increased from about 45 €/MWh to 50
€/MWh in the days across the end of 2024 and the beginning of 2025 but they very rapidly
dropped, and by the end of the first week of January 2025 prices were back to the pre-
Christmas level (45 €/MWh). Some commentators suggested that market operators may have
already factored the increase in the prices during 2024 before the halt of the transit. Even if
so, however, according to the few available estimates
73
developed in 2024
,
the expected price
increase was limited to 5% or less, which – at the current prices (approx. 35 €/MWh) - would
translate in a rise of 1-2 €/MWh.
74
73
74
see, for example,
Modelling based gas market analysis 2023/24 - REKK
REKK considers three demand scenarios: low 3000 TWh/y (~310 bcm), reference 3600 TWh/year (~370
bcm) and high 4100 TWh/year (~410 bcm). The EU demand in 2024 was about 330 bcm, so the low/reference
scenarios are the one more closely reflecting the current consumption in the EU. REKK also models a variety of
sensitivity analyses to account for potential changes in the market. It includes three different price environments,
35
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The price increase observed in the second half of 2024 and through the 2024/2025 winter
season was the result of a number of concomitant factors of which the anticipation of the end
of Ukrainian transit played, if any, a limited role. These factors include the depletion of
storage, the status of development of new liquefaction plants worldwide, some infrastructure
outage and disruption, lower renewable generation, the increase in the demand in the EU and
Asia, combined with a number of geopolitical events which contributed to create uncertainty
and fear of disruption, such as for example, the US sanctions against Gazprombank, China’s
import tariffs on US LNG, etc. As the end of the withdrawal season approached and the
tension linked to some factors mentioned above eased, gas prices gradually fell and returned
to the levels of summer 2024.
Figure 23: TTF month-ahead prices, Jan 2024 – mid-May 2024
Source: S&P Commodity Insights
4.3.2. Prohibition to provide services in EU LNG terminals to Russia’s customers
To effectively ensure the successful delivery of LNG imports from alternative sources, it is
crucial that LNG terminals within the Union make corresponding import capacity available to
these suppliers. As a significant portion of LNG capacity in certain Member States is
controlled by Russian entities, there is a risk that Russia obstructs alternative imports, notably
through not making unused capacities it had booked available to non-Russian importers after
the ban enters into force (hoarding), as seen in the case of storages in 2012/2022, or other
anti-competitive practices. To reinforce the ban on Russian imports, the proposal includes a
measure to make accessible to alternative suppliers the corresponding import capacity within
LNG terminals by prohibiting LNG terminal services to customers from Russia or customers
controlled by Russian undertakings by [1 January 2028]. This measure will redirect terminal
capacity to alternative suppliers, enhance energy market resilience, and address past issues of
market distortion, price increases, and threats to security.
namely 25, 35 and 45 €/MWh. Considering current prices at 35 €/MWh and a low to medium demand that the
impact is estimated to be below 5%.
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4.3.3. Transparency, monitoring, traceability and National Diversification Plans
The effectiveness of the proposed gas trade measures rest on three conditions:
-
transparency: the implementation of the measures - as designed in the proposal -
requires comprehensive and systematic information about the existing contracts for
Russian gas, including specific contractual arrangements (i.e. date of conclusion,
destination clause, duration, etc.) to establish when the contracts were established,
annual contracted volumes and their duration;
monitoring: the collection of information related to contracts is not only important for
the initial differentiation of contracts but also to enable customs, national energy
authorities and the Commission to assess the implementation of the measure and to
continuously monitor that no Russian gas will return to the EU in the future;
traceability: in order to make sure that gas of Russian origin cannot enter the EU,
customs authorities need to sort imported gas according to its origin. Except for cases
where gas can clearly be considered as of Russian origin, the proposal requires
importers to present documentation to the customs authorities about the origin of the
imported gas.
-
-
In order to ensure the effective phase-out of Russian gas, it is necessary to establish a
transparency framework that provides the Member States' competent authorities and the
European Commission with the relevant contractual information to precisely evaluate the
level of exposure of the EU to Russian imports.
A set of key contractual information, from importers of gas of Russian origin, is necessary for
the assessment, evaluation and monitoring of the EU’s exposure to Russian gas and the
implications for the EU’s security of supply.
To ensure a comprehensive documentation, the gas supply contract information should
include key details such as quantities to be supplied and taken, including flexibilities under
take-or-pay or deliver-or-pay provisions. The information provided should also specify the
conclusion date, contract duration, contracted gas quantities with upward or downward
flexibility rights, and the identities of the contract partners, gas producer, and country of
production. For LNG imports, the port of first loading should be reported, along with delivery
points and possible flexibilities regarding these points. Additionally, delivery schedules or
nominations, possible contractual flexibilities concerning annual quantities, and conditions
for suspension or termination of deliveries, including force majeure provisions should be
outlined. The governing law and chosen arbitration mechanism should also be specified, as
well as key elements of other relevant commercial agreements. Price information is not
necessary for the assessment by the Commission of the EU’s exposure to Russian gas
imports. Furthermore, any modifications to the contract, except those related to gas price,
should be documented. Overall, this comprehensive set of information will provide a clear
understanding of the gas supply contract's terms and conditions, and contribute to the
effective preparation of the phase out that ensures gas supply security.
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This transparency framework will be the cornerstone of a monitoring of the Union’s exposure
to gas of Russian origin, essential in the overall assessment of the EU’s security of supply
situation. Based on the abovementioned information provided by importers, the competent
authorities of the Member States and the European Commission, will be able to precisely
monitor the amount of Russian gas entering the Union, identify the actors involved, the entry
points and other key elements essential in the evaluation of the EU’s security of supply.
Additionally, Member States will be required to develop comprehensive national
diversification plans that detail concrete measures and timelines to phase out Russian gas
supplies. Establishing these national diversification plans for gas is essential for achieving the
objective of eliminating any dependence on Russian gas and will help provide businesses and
investors with the predictability and reassurance they need to make strategic investment
decisions to secure alternative gas supplies. The first national diversification plans should be
submitted by the end of 2025, to allow for a well-planned and secure phase out.
The information in the national plans will complement the information provided by importers
of Russian-origin gas. Together, this comprehensive set of data will inform the monitoring
process, enabling the European Commission to evaluate the European Union's exposure to
Russian-origin gas and assesses the effectiveness of Member States' strategies to phase out
these imports. his will contribute to the strengthening of the EU security of supply and the
preparation of markets to the phase out of Russian gas.
The Commission’s legislative proposal has specific targets for Member States to lay out:
•
•
•
the volume of Russian gas imports under existing contracts, including for contracts
with take-or-pay clauses;
75
a timeline, including milestones supporting EU measures to achieve the objective of
phasing out Russian gas;
diversification options, alternative supply routes and supplies, and technical
capabilities to replace Russian gas, including through cooperation in existing regional
groups;
any potential technical or regulatory barriers to replace Russian gas.
•
The Commission will support Member States in the preparation of the national diversification
plans, through established working and coordination groups, such as the Gas Coordination
Group, or a dedicated subgroup, as well as regional groups.
Once these national diversification plans are submitted, the Commission will assess the
implementation of the Russian gas phase-out at national, regional, and EU levels, and report
its findings to the Gas Coordination Group. An annual report will be published, providing a
detailed overview of the progress achieved by Member States in implementing their
diversification plans. If necessary, the report will be accompanied by Commission’s
recommendations outlining potential measures to ensure a secure and timely phase-out of
Russian gas. Relevant Member States will be required to update their diversification plans
within [three] months, incorporating the Commission's recommendations.
75
A take-or-pay contract is a type of agreement commonly used in the energy industry, particularly in gas sales.
This contract stipulates that the buyer must either take delivery of a specified amount of gas or pay a
predetermined penalty if they do not take the delivery.
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4.3.4. Supporting diversification by demand aggregation
Since 2023, AggregateEU has supported European companies in diversifying their gas and
LNG supplies away from Russia. Through 6 demand aggregation and matching rounds,
AggregateEU saw almost 190 companies engaging to seek best opportunities for gas and
LNG supplies through to 2030. By way of example, the second mid-term round of demand
aggregation and matching under AggregateEU was completed on 26 March 2025 and
gathered significant interest on both the demand and the supply side, with 29 bcm of demand,
31 bcm of supply offers and almost 20 bcm of matched supply-demand interests. It covered
gas demand between 2025 and 2030 and allowed buyers to indicate a preferred terminal in
the EU or deliveries free-on-board, providing buyers with additional flexibility.
In a fast-changing market environment, the context of the phase out of Russian gas, the
experience gained with AggregateEU serves as a basis to offer targeted support to EU LNG
buyers to find alternative suppliers. Looking forward, options going beyond demand
aggregation should also be explored in view of harnessing EU purchasing power to support
its diversification efforts.
Beyond LNG, in the mid- to long-term, the Commission’s new suite of mechanisms will help
companies find counterparts to contract for clean energy carriers, such as hydrogen and its
derivatives, and biomethane.
4.4.
Legal considerations on the impact on existing long-term contracts
Long-term supply contracts have an important role in the international gas industry, for both
pipeline gas and LNG. Notwithstanding the emergence and increasing role of shorter-term
alternatives, substantial volumes of pipeline gas and LNG continue to be traded under long-
term contracts which has remained a crucial contractual instrument for international gas and
LNG sales. By offering predictability and stability, they sustain project financing of energy
projects and the construction of pipeline gas and LNG infrastructure that require large upfront
investments. Despite similarities, the wording of each long-term contract is specific and
tailor-made by the buyer and the seller.
While not obligatory, a common feature of long-term supply contracts is the inclusion of
‘take-or pay obligation clauses. A ‘take-or-pay' clause means that the buyer must either accept
a minimum quantity of goods or services or pay an agreed price for not taking them. The
minimum quantity is usually set as a percentage of the contracted quantity. This percentage
typically varies from one contract to another within a range of between 70 – to 100 per cent.
In long-term contracts with ‘take-or-pay’ clauses, so-called ‘Force Majeure’ events may
excuse the buyer from liability for non-performance of its ‘take-or-pay' obligation. ‘Force
Majeure’ may be defined differently, depending on the applicable law of the respective
contract. Typically, ‘Force Majeure’ refers to unforeseeable events which could not be
expected at the time of the signature of the contract, and which prevent a party to the contract
to perform the contractual obligations due to external circumstances beyond a party’s
reasonable control. Contracts may include specific conditions for ’Force Majeure’ often
providing for examples, as a result of the agreement between parties. Examples of ‘Force
Majeure’ events that can qualify under ‘acts of government’ can be laws, regulations, and
other acts imposed by governments or public authorities that directly affect the ability of the
party to perform its contractual obligations.
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A legal prohibition of imports of natural gas under a Union trade measure constitutes a
sovereign act of the Union beyond the control of gas importers and rendering the
performance of natural gas imports from Russia unlawful, with direct legal effect and without
any discretion for Member States concerning its application.
5. Measures on Russian oil supplies
The legislative proposal mandates those Member States, which still import Russian oil via
pipelines, to plan and monitor phase out through national plans. In the Roadmap towards
ending Russian energy imports the Commission announced additional actions to address
Russia’s shadow fleet transporting oil and circumventing EU sanctions. These will be put
forward in the context of the Common Security and Defence Policy, not constituting a
legislative act but legally binding measures.
5.1. Assessment of the effects of the proposal
The phase out of Russian oil by 2027 as envisaged in the roadmap would not raise security of
supply concerns
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.
First, the Adria pipeline represents a valid alternative to replace the remaining Russian
pipeline supplies. The Adria pipeline starts in the Croatian port of Omisalj, goes through
Hungary and connects to the Druzhba pipeline in Šahy (Slovakia). The pipeline has a
capacity of about 11.4 million tonnes per year, possibly reaching 14.2 million tons per year
by adding Drag reducing agent polymers. Currently the pipeline is underutilised (about 80 %
of capacity is unused) with existing annual contracts running until the end of 2025 for 2.1
million tons to Slovakia and Hungary. The Adria pipeline has sufficient capacity to cover the
entire demand of Slovakia and Hungary, the only two Member States still importing crude oil
from Russia (5.2 million tonnes for Slovakia and 6.2 million tonnes for Hungary) as
confirmed by Slovakia’s National Energy and Climate Plans
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.
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This part focuses on Russian remaining imports of crude oil via pipeline. Russian seaborne imports
have been almost entirely phased out thanks to the EU sanctions adopted in 2022. However, some
small volumes of natural gas liquids from Russia are still reported by Eurostat. Natural gas liquids
sometimes referred to as natural gas condensates, are liquid hydrocarbons recovered from natural gas
and oil field operations or oil/gas processing plants. They include ethane, propane, butane, and
pentanes and are used as feedstocks in the petrochemical industry. NGLs benefit from well supplied
global markets. Main NGL producers are the USA, Saudi Arabia, Mexico and Russia for a global
market of 13 million barrels per day in 2023 (source: IEA: Oil
2024 -Analysis and forecast to 2030).
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Slovakian plan:
MINISTERSTVO HOSPODÁRSTVA SLOVENSKEJ REPUBLIKY
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Figure 24: Pipeline links to European refineries
Source: S&P Global Commodity Insights
Moreover, refineries in Hungary and Slovakia are well in advanced in developing the
necessary technical capabilities to process crude oil from origins other than Russia. For
example, MOL, the oil company running the refineries in Hungary and Slovakia still
receiving Russian oil, announced that it will be able to fully refine non-Russian crude oil by
2026
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as already done by several other countries that used to import Russian oil through the
Druzhba pipeline (Germany, Poland, Czechia).
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Box 3: Czechia's successful phase out of Russian crude oil
Czechia, together with Hungary and Slovakia, has initially benefitted from the derogation on
the import ban. In 2023, Czechia imported about 85000 barrels per day (about 4 million
tonnes) of crude oil from Russia, accounting for about 60% of its imports, and the rest came
from the port of Trieste through the TransAlpine (TAL) and IKL pipelines.
About EUR 60 million was invested in the refit and modernization of the Trans Alpine
pipeline - so-called TAL-PLUS project – which enabled to significantly expand the capacity
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In its NECP, Hungary announced the plan of building a new oil pipeline between Hungary and Serbia with
planned capacity of 5 Mt/y with expected commissioning in 2028 to supply non-Russian crude oil to Serbia in
line with the current EU sanction regime. This confirms that Hungary is expecting to be able to import oil from
origins other than Russia (which would then re-export to Serbia).
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of transport. The technical work began in April 2023 and was completed in two years.
Figure 25: TAP-PLUS project
The TAL pipeline used to have a capacity of 43 million tonnes of crude oil per year, of which
3-4 million tonnes were delivered to Czechia. The TAL-PLUS project increased the
operational capacity to 49 million tonnes of oil per year, bringing the capacity available for
the Czech refineries to 8 million tonnes of oil per year, sufficient to cover Czech entire crude
oil consumption (6-7 million tonnes per year).
As of April 2025, Czechia no longer imports Russian oil through the Druzhba pipeline and it
is fully independent from Russian supplies. That was also made possible thanks to the
successful technical adaptation of the Litvínov refinery which is now capable to fully process
non-Russian crude oil. The adaptation work was completed in 2 years
The phase out of Russian supplies did not have any material consequences on retail prices in
Czechia. 6 below show that the evolution of Czech retail prices for the main fuels (gasoline
and diesel) and compare it with the EU average and the prices in the neighbouring Member
States which still import crude oil from Russia. Czech prices followed the EU trend and there
is no indication that prices have deteriorated compared to Hungary and Slovakia since
Czechia stopped imports from Russia.
Figure 26: retail prices (without taxes) of Euro-Super 95 and Diesel, Jan 2025 – 19 May
2025
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Source: oil weekly bulletin
Note: Euro-Super 95
Source: oil weekly bulletin
Note: Diesel
The impact on prices is expected to be limited. The market for crude oil is global and Brent –
the price benchmark commonly used in the EU and used to price about two thirds of the
internationally traded oil - reflects global oil market fundamentals and the global economy.
The waterborne crude oil necessary to replace the volume flowing through Druzhba (approx.
11.4 mt per year) would represent a minimal amount of the seaborne oil traded globally
(approx. 0.5%). Therefore, the additional demand to replace Russian oil would unlikely have
any material impact on the global balance and therefore on prices. In support of this, it can be
noted that Czechia has stopped importing Russian crude oil since April 2025 (approx. 4.3 mt
per year), replacing it with seaborne oil coming from the Mediterranean ports, and there is no
indication that this has had any appreciable impact on the international prices. On the
contrary, Brent is on a downward trend since January 2025, returning to levels last seen in
spring 2021. The Czech experience (see Box 3 above) also shows that phasing out Russian
oil, if anticipated and well-prepared, does not cause materially negative effects on local retail
prices.
Figure 27: Brent prices (USD/barrel), Jan 2025 – mid-May 2025
Source: S&P Global Commodity Insights
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Concerns were raised that the JANAF transport fees are higher than Druzhba’s. However,
transport fees represent about 3% of the crude oil prices and therefore, they have limited
effects on the wholesale prices. It is also possible to use alternative routes. For example,
seaborne crude oil could also flow from the Black Sea through the Odessa-Brodi pipeline
which is connected to the Druzhba pipeline in the Ukrainian territory.
5.2. National diversification plans
Member States will be required to develop comprehensive national diversification plans that
detail concrete measures and timelines to phase out Russian oil. Establishing these national
diversification plan for oil is essential for achieving the objective of eliminating any
dependence on Russian oil and will help provide businesses and investors with the
predictability and reassurance they need to make strategic investment decisions to secure
alternative oil supplies. The first national diversification plans should be submitted by the end
of 2025, to allow for a well-planned and secure phase out.
Concretely, the Commission’s legislative proposal has specific targets for Member States to
lay out:
•
•
•
the volume of Russian oil imports under existing contracts;
timeline, including milestones supporting EU measures to achieve the objective of
phasing out Russian oil;
potential technical or regulatory barriers to replace Russian oil.
The Commission will support Member States in the preparation of the diversification plans
where appropriate.
Once these national diversification plans are submitted, the Commission will assess the
implementation of the Russian oil phase-out at national, regional, and EU levels. If there is an
identified risk that the objective of phasing out Russian oil by 31 December 2027 may not be
achieved, the Commission will issue a recommendation, after assessing the plans, outlining
potential measures to achieve a secure and timely phase-out of Russian oil. Relevant Member
States will be required to update their diversification plans within [three] months,
incorporating the Commission's recommendations.
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