SEA-LNG, the industry coalition focused on LNG and renewable methane as marine fuels, has published a position paper calling on the European Commission's Directorate-General for Energy (DG ENER) to protect the mass-balance terminal chain of custody for liquefied biomethane (LBM) as it prepares revisions to the implementing framework for the Renewable Energy Directive (RED III).

The report, titled Liquefaction by Equivalence Pathways for Liquefied Biomethane: A Policy Framework to Enable Scalable Maritime Decarbonisation, argues that LBM delivered via mass-balance terminal pathways using liquefaction by equivalence is the lowest-cost and lowest-emission chain of custody for compliance under FuelEU Maritime and the EU ETS.

The coalition says LBM bunker volumes grew approximately 100-fold in 2025 compared with 2024, with the overwhelming majority delivered via the mass-balance terminal pathway. SEA-LNG claims the approach can leverage Europe's existing network of more than 33 LNG import terminals and around 200,000 km of gas transmission infrastructure without requiring new capital investment in liquefaction plants.

DG ENER is preparing proposed revisions to RED Annex V, Annex VI and Implementing Regulation (EU) 2022/996 — all of which will be binding on Member States and will determine the legal status, greenhouse gas accounting treatment and commercial viability of the mass-balance terminal chain of custody. SEA-LNG warns that inadvertent restriction of the pathway through narrow definitions, inflated default emission factors, or inconsistency between the instruments could reduce the availability of compliant low-carbon marine fuel and raise costs for European shipping.

Steve Esau, Chief Operating Officer of SEA-LNG, commented: "The global maritime sector faces a critical decarbonisation challenge with Europe playing an important role in this push. Liquefied biomethane is one of the few fuels capable of meeting Europe's maritime decarbonisation obligations at the scale and speed the regulations demand.

"The mass-balance terminal route, using liquefaction by equivalence, is why LBM bunkering grew a hundredfold last year. It uses infrastructure that already exists, so it is scalable and lower cost than the alternatives such as physical segregation. Such dramatic growth illustrates the maritime sector's appetite for decarbonisation. Europe has an opportunity to become a global leader in biomethane, e-methane and renewable methane pathways. Today, DG ENER can unleash Europe's energy potential."

SEA-LNG is calling on DG ENER to formally recognise liquefaction by equivalence and recondenser liquefaction as valid RED III mass-balance pathways, and to assign differentiated default greenhouse gas emission values for each liquefaction route based on measured operational data. The coalition is also urging full regulatory coherence between Annexes V and VI and Implementing Regulation (EU) 2022/996, as well as the preservation of cross-border mass-balance mechanisms — including cross-terminal nominations — consistent with single market principles.

Additionally, the coalition is pushing for long-term investment certainty through a stable regulatory framework extending beyond 2030. SEA-LNG argues that shipowners and operators face vessel capital commitments spanning 20 to 25 years and that regulatory instability could delay newbuild orders or prompt reflagging to non-EU jurisdictions.

SEA-LNG notes that mass-balance is not a new concept in the maritime sector, pointing to its established use as a chain of custody model for bio-based chemicals and plastics, agricultural commodities such as cotton, and sustainable aviation fuel under both CORSIA and ReFuelEU Aviation.