Solution: Compliance
Complying with the EU Methane Regulation: A Practical Guide for Producers and Importers
If you produce natural gas destined for the EU market — or import gas onto it — EU Methane Regulation compliance is the operational and documentation work your team has to be ready for by the 2027 reporting cycle. This page explains what Regulation (EU) 2024/1787 requires, who is in scope, what the operative articles mean in practice, and how Greentruth's QET-NG with its EU compliance extension produces the documentation pack the regulation expects.
EU Methane Regulation compliance, in one paragraph. Under Regulation (EU) 2024/1787, producers and importers placing natural gas on the EU market must provide chain-of-custody methane information across the supply chain (Article 28), verified by an accredited body to a reasonable-assurance standard (Article 8). Compliance is mediated by an equivalence demonstration anchored to OGMP 2.0 and the EEMDL Protocol (UT Austin Energy Emissions Modeling and Data Lab). Greentruth's QET-NG, with its EU compliance extension, produces the records and the verifier-of-record attestation the regulation expects.
Independent academic commentary. In April 2026, the Payne Institute for Public Policy at the Colorado School of Mines published Tracking and Transacting Clean Natural Gas: Operationalizing Environmental Attribute Tokens — commentary by Liam O'Byrne and Brad Handler. The paper uses EarnDLT's QET-LNG architecture as its illustrative example of a compliant attribute token under the EU Methane Regulation, framing the design as “a universal bridge between heterogeneous North American MRV practices and the EU’s harmonized reporting requirements.”
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Walk through a QET-NG with the EU compliance extension — Article 28, Article 8 verification, Article 27 importer pack, EEMDL reconciliation.
Regulation Overview
What the EU Methane Regulation Does
The EU Methane Regulation — Regulation (EU) 2024/1787 — extends the European Union's methane oversight from EU-domestic producers and operators (where the regulation has been in force since 2024) to the full value chain for gas placed on the EU market. The architecture is straightforward:
- Domestic side. EU operators (oil, gas, coal) face direct measurement, reporting, and leak-detection-and-repair (LDAR) obligations.
- Imported gas side. Non-EU producers and EU importers face equivalent obligations on the data and verification accompanying gas placed on the EU market.
For the imported gas side — where most non-EU producers and US LNG exporters interact with the regulation — the practical work of EU Methane Regulation compliance is twofold: assemble the chain-of-custody methane information the regulation expects, and have it verified to reasonable assurance by an accredited body.
Scope
Who Is in Scope
The regulation's reach extends across the natural-gas value chain. For the imported-gas side specifically, EU Methane Regulation compliance work touches:
- Non-EU upstream producers. Anyone producing natural gas (pipeline or LNG) that ultimately reaches the EU market.
- Midstream operators. Gathering, processing, and transmission operators whose data feeds the chain-of-custody record.
- LNG exporters. Specifically, parties contracting LNG cargoes for delivery into EU import terminals.
- EU importers. Entities placing gas (whether pipeline or LNG) on the EU market — they hold the importer-information duties under Article 27.
- Commodity traders and intermediaries. Where the trader is between the producer and the importer, the trader's contract documentation has to carry the methane data through.
- MRV teams and accredited third-party verifiers. The operational and assurance functions that produce and sign off on the data.
The practical implication: if your supply chain is exposed to EU markets at any point, EU Methane Regulation compliance is going to land on someone in your organization — and the operational lead time is longer than the calendar suggests.
Key Articles
The Operative Articles: 28, 8, 27, and 29
The regulation has many articles. Four matter most for compliance work today:
| Article | What it requires | Status |
|---|---|---|
| Article 28 | Chain-of-custody methane information across the supply chain for gas placed on the EU market | Operative |
| Article 8 | Reasonable-assurance verification of the underlying data by an accredited body | Operative |
| Article 27 | Importer information obligations — the duty sitting on the EU side of the import contract | Operative |
| Article 29 | Maximum methane intensity threshold for gas placed on the EU market | Forthcoming via European Commission implementing acts |
Article 28 is where the documentation work lives. Article 8 is where the verification work lives. Article 27 is the importer's mirror of Article 28. Article 29 is the forward-looking ceiling that will tighten the market — what threshold the implementing acts ultimately set will determine which producers and basins remain competitive on EU-bound supply.
Equivalence Demonstration
EU MRV Equivalence: The Architecture
Equivalence is the legal device that lets non-EU producers comply. Rather than requiring identical MRV to the EU domestic regime, the regulation asks whether the producer's MRV is of comparable rigor. European Commission implementing acts are working out where that line sits in practice.
Two anchors are operative for the equivalence demonstration today:
- OGMP 2.0 reporting (administered by UNEP IMEO). The five-level methane reporting framework; Level 4 (source-level measurement) and Level 5 (site-level reconciliation) are the tiers EU Methane Regulation compliance work most clearly anchors on.
- EEMDL Protocol (UT Austin Energy Emissions Modeling and Data Lab). The reconciliation vehicle Greentruth's QET-NG EU compliance extension uses to bring source-level (bottom-up) and site-level (top-down) measurements into agreement at tiered thresholds.
A producer reporting at OGMP 2.0 Level 4 or Level 5, with EEMDL reconciliation, third-party verified to ISO 14064-3 reasonable assurance, is in materially stronger equivalence posture than one relying on industry-average factors and limited-assurance attestations. The Payne Institute commentary (O'Byrne and Handler, April 2026) frames this exact architecture — measurement-standard-agnostic at the input layer, regulatorily compliant at the output layer — as the bridge that lets the EU's 1 January 2027 MRV-equivalence deadline, 5 August 2028 methane-intensity reporting, and 5 August 2030 maximum-intensity threshold all run on a single underlying QET record.
OGMP 2.0 & EEMDL
The Role of OGMP 2.0 and the EEMDL Protocol
A common confusion in early EU Methane Regulation compliance is treating OGMP 2.0 and the EEMDL Protocol as alternatives. They are not. They work in tandem:
- OGMP 2.0 is the reporting framework. It defines the five levels of reporting rigor — from generic factors at Level 1 up to site-level reconciliation at Level 5 — and is the public anchor the EU Methane Regulation references for equivalence.
- The EEMDL Protocol is the reconciliation methodology at the higher levels. It defines, in operational terms, how source-level bottom-up data is reconciled against site-level top-down measurements to a tiered threshold.
Together, OGMP 2.0 sets the level of rigor; EEMDL sets the methodology by which the highest levels are operationalized. Greentruth's QET-NG methodology v2.3 incorporates both in its EU compliance extension so that the resulting token meets both the framework anchor and the operational methodology in a single record.
QET-NG EU Extension
How a QET-NG With the EU Compliance Extension Produces the Documentation
A QET-NG with the EU compliance extension is structured to address Articles 28, 8, 27, and (when the implementing acts arrive) 29 from one underlying record. The token carries:
- The chain-of-custody record under Article 28. Producer, basin, transmission pathway (origin basin center, operator chain, segment count, total mileage across EarnDLT's pipeline network model), and the multi-pollutant carbon intensity in kgCO₂e/MMBtu using IPCC AR5 GWP100 factors (CH₄ = 28, N₂O = 265).
- The verifier-of-record attestation under Article 8. Accredited third-party verifier identity and the reasonable-assurance verification per ISO 14064-3.
- The OGMP 2.0 Level and EEMDL reconciliation tier. Recorded as token attributes so the documentation package can be reconstructed against the methodology version in force at issuance.
- The methodology version and reference dataset version (including R&D GREET 2025 where applicable).
- The importer's documentation pack under Article 27. The same QET-NG record feeds the importer-side obligations without parallel data assembly.
For the downstream side, GasTrace generates verified Scope 3 Category 3 EACs for EU gas consumers from the same EU-compliance-extended QET-NG records. EU coverage launches H2 2026 with an analogous pipeline network model.
Verification Standard
ISO 14064-3 Reasonable Assurance: The Verification Layer
Article 8 of the EU Methane Regulation requires reasonable assurance. The distinction between limited and reasonable assurance is the difference between a defensible disclosure and one that survives a verifier's review:
- Limited assurance. A “moderate” level of confidence; the verifier issues a negative-form opinion (“nothing has come to our attention…”). Adequate for some voluntary regimes; not adequate under Article 8.
- Reasonable assurance. A “high but not absolute” level of confidence; the verifier issues a positive-form opinion. The bar Article 8 sets.
Greentruth's QET-NG carries ISO 14064-3 reasonable-assurance verification at the token level. The verifier of record is stamped on the certificate at issuance — not produced separately at disclosure time, and not constructed retroactively.
Important Distinctions
What Complying Does NOT Mean
EU Methane Regulation compliance is not a carbon credit program, not an offset framework, and not satisfied by a self-declared methane attestation. It is a chain-of-custody documentation and reasonable-assurance verification regime. A QET-NG retirement substantiates a specific verified physical unit of gas — it does not transfer Scope 1 emissions between parties, and it is not a substitute for the operational measurement work the regulation requires.
Three corollaries about EU Methane Regulation compliance that producers and importers most often need to internalize:
- Limited-assurance attestations do not meet Article 8. The verifier has to operate under reasonable-assurance criteria, which is a materially harder bar than limited assurance and closer to financial-statement assurance.
- National or basin-average emission factors are not equivalence demonstrations. They may be acceptable as fallback data in some voluntary regimes; they are not what the European Commission's implementing acts treat as comparable rigor.
- The producer's Scope 1 inventory stays the producer's. A QET-NG documents the methane intensity of a specific unit of gas; it does not net or transfer the producer's inventory.
Frequently Asked Questions
EU Methane Regulation compliance is the obligation under Regulation (EU) 2024/1787 to provide chain-of-custody methane information across the supply chain for gas placed on the EU market (Article 28), verified to a reasonable-assurance standard by an accredited body (Article 8).
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Walk Through a QET-NG With the EU Compliance Extension
Request a demo and we will walk through a QET-NG with the EU compliance extension — Article 28 chain-of-custody, Article 8 verification, Article 27 importer pack, OGMP 2.0 Level alignment, EEMDL reconciliation, and the ISO 14064-3 verifier of record — produced from a single underlying record.underlying record.