REPORT FROM THE COMMISSION TO THE COUNCIL review on the functioning of Regulation (EU) 2022/1369 on coordinated gas demand reduction
Date: 2023-03-20
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, EU energy policy, energy consumption, energy crisis, energy demand, energy saving, gas supply, natural gas, security of supply, self-sufficiency in energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.3.2023  COM(2023) 173 final  REPORT FROM THE COMMISSION TO THE COUNCIL review on the functioning of Regulation (EU) 2022/1369 on coordinated gas demand reduction {SWD(2023) 63 final}  
 
 
I. 

Introduction 

In  the  course  of  2022,  Russia  used  gas  supplies  as  a  political  weapon.  In  this  context,  the  EU 
adopted in August 2022 the emergency Council Regulation (EU) 2022/1369, to reduce gas demand 
by 15% in a coordinated manner to ensure security of supply. 

According to Council Regulation (EU) 2022/1369, Member States must use their best efforts to 
reduce  gas  demand  by  15%,  which  becomes  mandatory  in  case  a  Union  alert  is  declared.  In 
addition,  Member  States  shall  update  their  emergency  plans,  as  set  out  in  Article  8  of  the 
Regulation  to  reflect  the  implemented  measures  and  report  the  demand  reduction  achieved  bi-
monthly to Eurostat. Article 9 provides that the Commission has to carry out a review, on the basis 
of  which  the  Commission  may  propose  to  prolong  the  Regulation’s  application  period.  In  the 
accompanying Staff Working Document SWD/2023/63, the Commission provides an analysis of 
the  gas  demand  reductions  since  August  2022,  a  scenario-based  analysis  of  storage  filling 
projections  under  different  potential  demand  reduction  extensions  and  a  deep-dive  into  past 
reductions and upside and downside risks for 2023-2024. 

The matter has been discussed with the Gas Coordination Group1, which includes representatives 
of  Member  States  and  European  associations  representing  suppliers,  infrastructure  operators, 
traders and the main consumers of gas. The members of the Gas Coordination Group during its 
meeting of 16 February have voiced their understanding of the importance of a continued demand 
reduction as a particularly cost-effective measure to preserve and strengthen security of supply. 

II.  Measures taken and demand reduction achieved 

Since  the  adoption  of  Council  Regulation  (EU)  2022/1369,  the  EU  has  been  successful  in 
diversifying away from Russian gas2 and reducing its gas demand by 19% from August 2022 to 
January 2023, compared to the previous 5 years’ average over that same period, which corresponds 
to  41.5  bcm.  Table  2  (see  Annex)  shows  that  the  demand  reduction  has  varied  from  month  to 
month, and from Member State to Member State, reflecting the different national circumstances. 
In the event of a Union alert, the exemptions of the mandatory demand reduction, as stipulated in 
Article  5  in  the  Council  Regulation  (EU)  2022/1369,  also  reflect  these  different  national 
circumstances. 

Current storage levels are relatively high for the time of the year, gas prices have steadily decreased 
since the peaks in August (while still being significantly higher than the long-term average), and 
security of supply is assured for the remainder of this winter 2022/2023. However, Section III will 
illustrate that the EU gas market remains tight, and that without any gas demand reduction beyond 
31 March, the Member States are unlikely to fulfil their 90% storage obligation by 31 October, 

1 Register of Commission expert groups and other similar entities (europa.eu) 
2 In 2022, Russian gas supplies to the EU decreased by 47% from 152 bcm in 2021 to 80 bcm. They were replaced 
mainly by the United States that increased its exports from 21 bcm to 50 bcm and the United Kingdom increasing 
supplies from 6 to 24 bcm. Further increases in gas supply to EU came from Norway (+10 bcm), Azerbaijan (+3 
bcm), Qatar (+2 bcm) and Trinidad and Tobago (+1 bcm). 

1 

 
 
                                                           
putting at risk the security of supply during the winter 2023/2024, with possibly gas shortages or 
a return of very high gas prices. 

Figure 1 illustrates EU gas consumption from August 2022 to January 2023 (green line; “Actual”) 
compared to the average of the same period during the previous 5 years (blue line; “Reference”) 
and the 15%-reduction target (red line; “Target”) as it has been defined for August 2022 to March 
2023, and as it would apply according to this proposal to the other months. Figure 1 also shows 
that gas consumption in winter is significantly higher than in summer. In fact, demand in Q2 and 
Q3 is around one-half of the demand in Q1 and Q4.  

Figure  1:  Reference  consumption,  target  consumption  (i.e.,  reference  -15%)  and  actual 
consumption (Aug. 2022 – Jan. 2023); EU27 (bcm) 

Source: ENER/CET calculations based on Eurostat series NRG_CB_GASM, sub-series IC_CAL_MG in mcm as of 7 
March 2023, 11:00. 

Sectors 

For an in-depth analysis of gas demand reduction, a frequent publication of sectoral gas demand 
is necessary. Currently, Eurostat reports gas consumption by demand sector3 only on an annual 
basis, with a one-year delay. A reliable breakdown of gas savings by sector or a breakdown into 
structural versus non-structural reductions based on an official dataset covering all EU is therefore 
not possible.  

The Commission4, using auxiliary data, estimates that in the period August-December 2022 the 
household reduction  accounted for around 50% and the industry for 43%, while the power sector’s 

3 Power generation is the only sector for which official Eurostat data are available; 2.1% reduction between August 
2022 and January 2023 based on Eurostat series NRG_CB_GASM, sub-series TI_EHG_MAP in TJ (GCV) as of 7 
March 2023, 11:00. 
4 DG Joint Research Centre 

2 

 
 
 
                                                           
accounted for only 7% of the overall gas demand reduction, due to low availability of hydropower 
and nuclear capacity.5 Industry was responsible for most of the demand reduction in summer and 
autumn, while households were responsible for most of the demand reduction (and consumption) 
in  winter.  We  estimate  that  around  one-sixth  of  the  total  reduction  was  temperature-induced, 
meaning that  it can be attributed to  a milder (early) winter than in  the reference period, which 
corresponds to 5 bcm out of a total reduction of 30 bcm between August and December.  

Member States’ measures reported in the Emergency Plans 

Articles 7 and 8 of Council Regulation (EU) 2022/1369 stipulate that Member States must notify 
demand reduction measures implemented, via an update of their emergency plans. The majority 
of Member States notified the Commission of their updated Emergency Plans. 

According  to  the  updated  plans,  short-term  measures  cover  two  main  types  of  measures:  (1) 
information campaigns on gas savings and (2) measures to reduce heating and cooling.  

  Most  Member  States  implemented  communication  campaigns.  In  some  instances,  the 
campaigns  also  raise  awareness  of  existing  subsidy  schemes  for  energy  efficiency,  mostly 
targeting households and SMEs.  

  Temperature limitation: most plans include heating and cooling restrictions in public buildings; 

some Member States extend this limitation to offices and shops.  

  Several Member States imposed lighting limitations, usually concerning public buildings and 

monuments but in some instances also shop windows. 

For medium-term measures, Member States notified fuel switching measures, subsidies for energy 
renovation of buildings or replacement of inefficient appliances. As long-term measures, Member 
States  often  provide  direct  support  to  customers  involving  subsidies  or  tax  cuts  to  facilitate 
deployment of renewables, heat pumps or energy efficiency (also via e.g. audits). 

III.  Outlook for the next winter 

While  the  EU  successfully  reduced  demand  between  August  2022  and  January  2023,  and 
diversified away from Russian imports, this section explores whether this is sufficient to avert any 
supply risk in the winter 2023/2024 if the Regulation (EU) 2022/1369 expires on March 31, 2023. 
Table  1  shows  the  storage  levels  for  October  2023  and  March  2024,  under  different  potential 
demand reduction extensions, based on the latest available market intelligence and data.6  Figure 

5 While using different reference periods, preliminary analysis by Bruegel (2023)  and the IEA (2023) , using auxiliary 
data, estimate similar magnitudes. 
6  Assumptions: 

Storage levels as of 7 March 2023 (58.5 bcm at the end of 5 March). 

- 
-  Non-Russian pipeline supply equal to the average of the last seven months of 2022. 
-  LNG supply equal to the average of the last seven months of 2022, plus 15  bcm/a (1.25 bcm/month) from 

Apr. 2023. 

-  No gas from Russia via pipeline. 

3 

 
 
                                                           
2 projects the storage filling levels for the 4 scenarios. Table 1 shows that in case of no or a limited 
gas demand reduction after April 1 (Scenarios A or B), Member States are unlikely to comply with 
the storage filling obligation of 90% by 31 October 2023, as set out by Regulation (EU) 2022/1032, 
and,  hence,  security  of  supply  for  winter  2023-24  cannot  be  ensured.  If  the  -15%  gas  demand 
reductions continue after 1 April until 31 October, at least, the 90% storage obligations are likely 
to be reached (Scenarios C and D). An extension of the gas demand reduction until 31 March 2024 
reduced the security of supply risks in a decisive manner for the winter 2024/2025. 

In  its  report  of  12  December  20227,  the  International  Energy  Agency  (‘IEA’)  estimates  that  a 
supply gap could occur in 2023 unless additional actions to save gas are taken. 

Table 1: Monthly storage levels depending on the extension of the demand reduction 

Scenario assumptions                    Storage (bcm) at the end of:  Oct. 2023  Mar. 2024 
A: No extension 
B: Extension for August 2023 to March 2024 
C: Extension for April 2023 to October 2023 
D: 1-year Extension for April 2023 to March 2024 

0 
28 
9 
43 

69 
80 
95 
95 

  Source: ENER/CET calculations. 

  Scenario A: No extension: If instead there were no demand reduction, storage levels would 
only  reach  69  bcm  by  the  end  of  October  2023,  significantly  below  the  90%  storage 
obligation  (89.4  bcm).  In  addition,  storage  levels  would  be  fully  depleted  by  February 
2024, implying very serious security of supply concerns for the winter 2024/2025.  

  Scenario B: 8-month extension for August 2023 to March 2024: In this scenario, storages 
would be filled too slowly, reaching only 80 bcm by the end of October, significantly below 
the 90% storage obligation (89.4 bcm). In addition, storage levels  would drop to below 
30% (28 bcm) by the end of next winter (28% at the end of March 2024), causing serious 
security  of  supply  concerns  and  making  it  difficult  to  fill  storages  sufficiently  for  the 
following winter 2024/2025.  

  Scenario C: 7-month extension for April to October 2023: In this scenario, storages would 
be sufficiently filled by the end of this summer 95% (95 bcm) by the end of October 2023, 
reaching  the  90%  storage  obligation  (89.4  bcm).  However,  because  demand  even  in  a 
normal winter is twice as high as in summer, storages would be almost fully depleted by 
the end of next winter (9 bcm by the end of March 2024). This implies very serious security 
of supply concerns and makes it very difficult to fill storages sufficiently for the following 
winter 2024/2025. 

-  Average demand of the reference period, applying percentage reductions as stated. 
-  Exports to Switzerland as in 2021 (latest data available; 2.2 bcm/a, of which 1/3 in summer and 2/3 in winter). 
-  Exports to Ukraine and Moldova of 0.5 bcm/month.  

7 IEA (2022): How to Avoid Gas Shortages in the European Union in 2023. A practical set of actions to close a 
potential supply-demand gap, How to Avoid Gas Shortages in the European Union in 2023 – Analysis - IEA  

4 

 
 
                                                           
  Scenario  D:  1-year  extension  for  April  2023  to  March  2024:  With  a  continued  15% 
demand reduction, storage levels reach 95 bcm by the end of October 2023, reaching the 
90% storage obligation (89.4 bcm). The storage levels would be around 43 bcm by the end 
of March 2024. 

Figure 2: Monthly storage levels depending on the extension of the demand reduction 

Monthly storage levels (bcm)

100
90
80
70
60
50
40
30
20
10
0

None

Same 8-month period (Aug '23 - Mar '24)

7-month summer (Apr-Oct '23)

Full year (Apr '23 - Mar '24)

Source: ENER/CET calculations. 

Moreover, and complementing the previous analysis in Figure 1 and Table 1, a number of factors 
and risks for this year and the next winter that may increase the gas consumptions8. These include 
a possible rebound in global LNG demand (limited as the EU remains the premium market9), a 
rebound of industrial gas demand and a reversal of the gas-to-coal switch (both driven by lower 
gas prices in 2023), weather conditions which could affect heating demand in winter10, and low 
nuclear and hydro power generation (due to droughts), as well as further gas supply disruptions. 
French nuclear capacity is currently below the availability in 2022, water levels in Italy are at 2022 
levels indicating similarly low hydropower generation and low gas prices already led to coal-to-
gas switch in the first weeks of 2023 (see section IV.3 of the SWD/2023/63). If these risks further 
materialize, they will constrain the global and European gas market and this could affect the filling 

8 IEA (2022): How to Avoid Gas Shortages in the European Union in 2023. A practical set of actions to close a 
potential supply-demand gap, How to Avoid Gas Shortages in the European Union in 2023 – Analysis - IEA 
9 Other parties in the global market do not compete above a certain level of natural gas prices since they switch to 
other fuels. 
10 According to ENTSOG, a very cold winter occurring with a probability of 5% would increase demand by 24 bcm. 
See Figure 1 (with an assumed 15% demand reduction) in ENTSOG’s winter supply outlook 2022/2023, available at:  
https://entsog.eu/sites/default/files/2022-10/SO0038-22_Winter%20Supply%20Outlook_2022-23_2.pdf.  This  is  in 
line with ENER/CET calculations of 28 bcm additional demand for the entire year in case the 15% demand reduction 
is applied not to the average demand of the past 5 years but to the highest demand of the 2014-2021 period for each 
month (monthly data are not available for earlier years).   

5 

 
 
 
                                                           
of underground storage facilities required for the winter 2023-2024, the gas price levels and the 
volatility of these prices. 

IV.  Outlook 

Despite  significant  improvements  since  August  2022,  the  situation  on  the  global  gas  market 
remains  tight  in  2023.  Several  factors  (weather,  remaining  Russian  imports,  the  availability  of 
alternative electricity sources and further tightness in global LNG markets) could make the 2023 
storage  filling  season  difficult.  Importantly,  contrary  to  the  preceding  filling  season,  the  2023 
storage filling cannot count on the 60 bcm of Russian pipeline gas that was still imported into the 
EU in 2022. In order to limit the risks for security of supply and the corresponding market impacts, 
a continued demand reduction is necessary. To decide whether and how to secure such reduction 
of gas demand in the Union, the following considerations are particularly important:  

1)  Global supply of natural gas remains tight. The share of Russian pipeline gas in total EU 
imports has decreased from 49% before January 2022, to less than 10% in January 2023. In 
2022, during the refilling season Russian pipeline imports were significantly higher than those 
expected  in  2023.  Reducing  demand  is  thus  necessary  in  light  of  these  reduced  Russian 
supplies.  

2)  Demand  reduction  would  reduce  the  price  volatility. While  the  worst  economic  impacts 
have been averted in 2022, global gas markets remain very constrained in 2023. Gas prices 
have reached historical highs in 2022 with a maximum price over 320 €/MWh on 26 August 
and they are below 45 €/MWh, but still at a level twice as high as the historic norm. During 
the Gas Coordination Group meeting of 16 February 2023, Member States’ representatives as 
well as gas associations acknowledged the fundamental role of demand reduction to reduce 
the pressure on a tight market and to contain the gas price volatility.  

3)  The  same  spirit  of  solidarity  which  has  prevailed  in  the  application  of  Regulation  (EU) 
2022/1369  should  continue.  The  current  legal  framework  for  security  of  gas  supply  set  by 
Regulation (EU) 2017/1938 remains insufficient to address disruptions of a major gas supplier 
lasting more than 30 days. Long-lasting disruptions could still lead to a risk of uncoordinated 
action by Member States, threatening to endanger security of supply in neighbouring Member 
States and to place an additional burden on the Union’s industry, consumers, and functioning 
of the internal market. While some Member States are more exposed to the disruptions than 
others,  any  gas  supply  difficulties  or  shortages  would  cause  harm  to  the  economies  of  all 
Member States.  

4)  As set out in the Communication “Save Gas for a Safe Winter” of 20 July 2022, it is cheaper 
for citizens and industry to continue proactively reducing demand in a proportionate and 
demonstrably manageable manner rather than face uncoordinated curtailments later.  

5)  A -15% demand reduction is in line with the 90% storage obligation: Scenarios C and D 
show  that  a  -15%  reduction  ambition  level  starting  from  1  April  2023  is  appropriate  and 
necessary,  and  allows  the  EU  to  reach  the  90%  storage  obligations  at  the  end  of  October, 

6 

 
 
 
including the possibility of moderate downside risks to occur (e.g. less LNG supply, low hydro 
levels or a moderately colder-than-average weather). 

6)  The continuation of the gas demand reduction is urgent to provide certainty to market 
participants. The current regulation expires on 31 March 2023, at the end of the winter season. 
Continuing the reduction effort from 1 April provides clarity and avoids an on-off messaging 
on incentives.  

7)  Only  an extension of the gas demand reduction  covering 12  months ensures sufficient 
storage  filling  over  the  summer  to  comply  with  the  storage  regulation  and  security  of 
supply next winter, as presented in section III. By contrast, an extension for reduction period 
August to March would leave insufficient time to fill storages at the appropriate 90% level, 
and lead to security-of-supply concerns towards the end of next winter. Cold weather alone 
would almost fully deplete storages by 31 March 2024. Alternatively, with an extension for 
April  to  October,  storages  would  be  almost  completely  depleted  by  31  March  2024,  even 
without cold temperatures and without any of the other downside risks materialising. In other 
words, extensions shorter than 12 months may lead to panic buys, Member States outbidding 
each  other  (without  more  gas  supplies  coming  to  the  EU  market),  high  prices  and  possible 
shortages. A more detailed analysis can be found in section VI of the SWD/2023/63. 

8)  A longer period gives more flexibility to optimise the spreading of the demand reduction 
efforts  over  time.  In  particular  it  would  reduce  the  possibility  of  price  spikes  and 
therefore limit the cost of gas purchases for Member States for the same volumes. Hence 
an  extension  with  a  12-month  reduction  period  allows  for  more  flexibility  to  cater  for  the 
different  characteristics  between  Member  States,  as  some  Member  States  find  it  easier  to 
reduce demand in summer (frontloading) and others find it easier to reduce demand in winter 
(backloading). In addition, it would allow flexibility between sectors: since residential demand 
is low in summer, an extension from April to October would put the burden disproportionately 
on  industry  and  the  less  flexible  power  sector,  which  is  dependent  on  the  availability  of 
alternative power sources. 

9)  Because of the two-monthly monitoring and lack of a more sectoral reporting during the 
implementation period August 2022 to March 2023, the nature and sectoral distribution 
of  these  demand  reductions  are  not  fully  understood.  This  limited  the  capacity  of  the 
Commission  and  the  Member  States  to  identify  the  sectoral  vulnerabilities  and  potential 
savings  (power,  industry,  residents  and  services)  and  hence  to  design  more  cost-effective 
measures s. 

7 

 
 
  
 
V.  ANNEX 

Table 2 summarises monthly gas demand reductions compared to the reference period. It shows 
that voluntary demand measures achieved the 15% reduction objective between August 2022 and 
January 2023. The EU’s 19.2% reduction corresponds to approx. 41.5 bcm, compared to a 15% 
target of approx. 32.5 bcm for these 6 months and a target of approx. 45.3 bcm for August 2022 to 
March 2023. 

Table 2: Gas demand reductions August 2022 to January 2023 

Aug. 
-13.5% 
-26.7% 
-1.0% 
-14.9% 
-21.7% 
- 
-15.0% 
-21.7% 
-37.1% 
-35.7% 
1.6% 
-28.0% 
4.5% 
-18.7% 
11.3% 
-5.2% 
-42.6% 
-43.6% 
-36.4% 
4.6% 
-29.7% 
-26.7% 
-10.7% 
-25.2% 
10.6% 
-13.7% 
2.6% 
-27.3% 

Member State 
EU27 
Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia* 
Slovenia 
Spain 
Sweden 

-22.2% 
-23.9% 
-18.3% 
-29.4% 
-24.2% 
- 
-24.0% 
-26.5% 
-38.0% 
-63.1% 
-19.2% 
-18.6% 
-36.7% 
-27.4% 
-4.3% 
-22.7% 
-37.0% 
-51.5% 
-25.0% 
21.9% 
-32.2% 
-12.0% 
-34.9% 
-21.0% 
-7.8% 
-14.7% 
-23.9% 
-41.9% 
Note: Change in gas consumption 2022 cf. 2017-2021 average. Cyprus does not use natural gas.  
Source: ENER/CET calculations based on Eurostat series NRG_CB_GASM, sub-series IC_CAL_MG in TJ (GCV) as 
of 7 March 2023, 11:00. 
* Eurostat data for Slovakia is currently under review. 

Jan.  Aug.-Jan. 
-19.2% 
-19.2% 
-16.0% 
-23.9% 
-24.1% 
- 
-17.7% 
-24.9% 
-36.2% 
-58.5% 
-17.1% 
-19.4% 
-22.7% 
-21.0% 
-0.3% 
-18.6% 
-31.8% 
-40.5% 
-27.7% 
+12.1% 
-29.5% 
-14.9% 
-17.1% 
-21.2% 
+4.6% 
-14.2% 
-13.7% 
-40.2% 

Dec. 
-12.4% 
-13.6% 
-9.8% 
-21.8% 
-27.6% 
- 
-10.9% 
-13.7% 
-32.4% 
-65.1% 
-8.3% 
-4.7% 
-12.6% 
-17.5% 
9.5% 
-18.5% 
0.9% 
-11.9% 
-17.5% 
27.0% 
-17.5% 
-5.3% 
-18.6% 
-15.9% 
23.6% 
-12.4% 
-24.4% 
-38.0% 

Oct. 
-24.4% 
-24.0% 
-20.5% 
-32.7% 
-20.0% 
- 
-22.9% 
-31.1% 
-46.9% 
-62.6% 
-27.8% 
-28.6% 
-42.0% 
-33.9% 
-8.8% 
-19.8% 
-72.7% 
-50.8% 
-35.5% 
-11.2% 
-33.3% 
-23.7% 
-12.0% 
-27.5% 
2.1% 
-22.2% 
-6.2% 
-41.8% 

Sep. 
-14.0% 
-11.3% 
-6.0% 
-17.8% 
-23.1% 
- 
-9.1% 
-23.3% 
-31.7% 
-57.4% 
-2.5% 
-14.7% 
-26.3% 
5.0% 
2.1% 
-14.0% 
-52.7% 
-45.0% 
-26.1% 
-1.1% 
-32.6% 
-25.4% 
-17.0% 
-20.7% 
5.5% 
-10.9% 
0.7% 
-35.7% 

Nov. 
-25.0% 
-16.9% 
-29.7% 
-21.2% 
-25.6% 
- 
-18.8% 
-33.4% 
-32.3% 
-58.3% 
-29.3% 
-28.3% 
-23.0% 
-19.8% 
-10.3% 
-22.7% 
-15.2% 
-46.0% 
-33.2% 
43.6% 
-35.1% 
-8.3% 
-8.9% 
-21.8% 
-2.7% 
-11.7% 
-21.8% 
-51.0% 

8