Proposal for a COUNCIL RECOMMENDATION on continuing coordinated demand-reduction measures for gas
Date: 2024-02-27
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

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   EUROPEAN COMMISSION  Brussels, 27.2.2024  COM(2024) 101 final 2024/0054 (NLE)  Proposal for a COUNCIL RECOMMENDATION on continuing coordinated demand-reduction measures for gas  
 
EXPLANATORY MEMORANDUM 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

Following  Russia's  invasion  of  Ukraine,  the  flow  of  gas  from  Russia  to  the  EU  has  been 
intentionally  disrupted  in  a  deliberate  effort  to  use  energy  as  a  political  weapon.  The  EU 
relied on Russia for ca. 45% of its gas supplies in 2021. Since February 2022, this share has 
continuously  dropped.  In  2023,  the  Union  imported  approximately  25  billion  cubic  meters 
(bcm) of Russian gas via pipelines.  Russian gas accounted for 15% of the EU’s total imports 
(pipeline and LNG) in 2023. Due to the supply disruptions and the tightness experienced on 
the  market  since  February  2022,  twelve  Member  States  activated  the  first  or  second  crisis 
level  pursuant  to  the  common  EU  classification,  as  foreseen  by  the  Gas  Security  of  Supply 
Regulation (EU) 2017/1938. 

The  disruption  of  gas  supply  had  marked  effects  on  the  price  and  volatility  of  gas  and 
electricity,  on  inflation,  and  on  the  EU’s  general  financial  and  macroeconomic  stability,  as 
well  as  the  economic  well-being  of  its  citizens.  The  2022  wholesale  price  was  on  average 
more  than  five  times  higher  than  before  the  crisis  triggered  by  the  Russian  invasion  of 
Ukraine in February 2022 and even spiked above 300 €/MWh at the peak of the crisis in the 
summer of 2022. Since February 2022, price levels were at higher levels than in the pre-crisis 
period, with continued strong price volatility. Competitiveness of EU businesses, in particular 
energy-intensive  industries,  was  negatively  affected  while  citizens  face  reduced  purchasing 
power. 

In  this  context,  the  Commission  proposed  on  20  July  2022  a  Council  Regulation  on 
coordinated gas demand reduction, which was adopted as Regulation (EU) 2022/1369 by the 
Council on 5 August 2022. Since the adoption of Regulation (EU) 2022/1369, Member States 
have implemented it by adopting measures to reduce their respective gas demand by 15%.  

Regulation  (EU)  2022/1369  provides  for  a  voluntary  Union–wide  demand  reduction  of  gas 
consumption of 15%. It also specifies that if voluntary demand-reduction measures prove to 
be insufficient to address the risk of a serious supply shortage, or on request from five or more 
competent authorities of Member States that have declared national alerts, the Council may, 
on  a  proposal  from  the  Commission,  declare  a  Union  alert  by  means  of  an  implementing 
decision. This Union alert would make the 15% demand reduction target mandatory and acts 
as a safety net in case of a crisis. 

Since  the  adoption  of  Regulation  (EU)  2022/1369,  he  EU  already  reduced  gas  demand  by 
18% on a voluntary basis between August 2022 and December 2023 (ca. 101 bcm saved). The 
continued need to  keep reducing  gas demand to  ensure security of supply and contain price 
volatility  led  the  Council  to  prolong  the  Regulation  by  1  year  until  31  March  2024.  As 
showcased  by  Commission  report  COM(2024)  88,  the  demand  reduction  efforts  were  the 
largest contributor to replacing the missing Russian pipeline gas, with ca. 65 bcm of gas saved 
in 2023.  

Member States need to remain prepared for possible severe shortages of gas in a coordinated 
fashion and in a spirit of solidarity. Despite the measures taken, severe difficulties persist in 
the  supply  of  energy,  which  can  affect  the  general  energy  security  situation,  if  the  demand 
does not remain below a safe level. The global gas markets remain tight and are expected to 
remain as such for some time as only very limited new LNG liquefaction capacity globally is 
planned to be operational before 2026. 

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Additional  risks  include  a  further  deterioration  of  geopolitical  threats  affecting  supplying 
regions, a possible rebound of LNG demand in Asia which can reduce the availability of gas 
on  the  global  market,  weather  conditions  which  can  affect  hydropower  storage  and  nuclear 
production and require a higher recourse to gas-fired power generation and further gas supply 
disruptions,  which  can  affect  the  filling  of  underground  gas  storage  facilities  required  for  a 
safe winter 2024-2025.  

Furthermore, Commission report COM(2024) 88 includes several scenarios, which, in case of 
a  Russian  disruption,  highlight  the  need  for  a  sustained  demand  reduction  to  ensure  storage 
filling and security of supply for 2024-2025. A full Russian supply disruption is an important 
scenario  to  consider,  among  others  due  to  the  end  of  the  current  transit  agreement  through 
Ukraine  by  31  December  2024  and  potential  further  escalating  geopolitical  tensions. 
According  to  these  scenarios,  if  demand  were  to  rebound  to  pre-crisis  levels  in  case  of  a 
Russian disruption (i.e. no sustained demand reduction), storages may be depleted already as 
soon  as  February  2025.  This  would  leave  the  EU  without  the  needed  volumes  to  supply 
consumers during the remainder of the 2024-2025 winter. In addition, the EU would start the 
2025-2026  storage  filling  season  at  record  low  levels,  meaning  that  security  of  supply  for 
2025-2026 would be at risk as well. The risks to security of supply in case of a full Russian 
disruption  are  also  acknowledged  by  the  European  Network  of  Transmission  System 
Operators  for  Gas  (ENTSOG)  in  its  Winter  Supply  Outlook.  ENTSOG  concluded  that 
although the general security of supply situation in the EU has improved, additional measures 
may  be  needed  to  secure  gas  supply  and  demand  adequacy  in  case  of  a  full  Russian 
disruption. The European Union Agency for the Cooperation of Energy Regulators (ACER) 
also  acknowledged  in  its  opinion  on  the  ENTSOG  Winter  Supply  Outlook,  that 
materialisation of risks may lead to supply scarcity, and that vigilance regarding the security 
of supply situation and implementation of gas demand reduction should continue.  

To  ensure  that  the  EU  is  prepared  for  the  winter  2024-2025  and  to  guarantee  that  Member 
States comply with the 90% storage filling target of 1 November 2024, careful management 
of  storages  remains  pivotal  and  should  remain  at  a  sufficiently  high  level  throughout  the 
winter.  In  2023-2024,  like  in  2022-2023,  demand  reduction  has  been  essential  to  keep 
adequate storage levels at the end of winter and to provide the necessary flexibility in summer 
so  that  the  90%  storage  target  could  be  met,  while  keeping  prices  to  lower  levels  and 
containing  volatility. The demand reduction measures played a  crucial  role in  achieving the 
storage target already in August, well before the target of November. Consequently, European 
market participants began to store gas in Ukraine towards the end of the summer in 2023.  

Therefore,  considering  the  risks  regarding  the  Russian  supply,  the  currently  deteriorating 
geopolitical threat landscape, the weather conditions and the global gas market developments, 
it is proposed to recommend that Member States continue their coordinated demand-reduction 
measures, after the expiration of the period of the Regulation (EU) 2022/1369. While Member 
States  face  a  varying  degree  of  exposure  to  supply  disruptions,  any  gas  supply  shortages 
would cause harm to the economies of all Member States. As set out in the Communication 
“Save Gas for a Safe Winter” of 20 July 2022, it is economically more sustainable for citizens 
and industry of all Member States, in a spirit of solidarity, to continue reducing demand in a 
proactive  and  proportionate  manner  rather  than  face  uncoordinated  curtailments  later. 
Proactive,  coordinated  and  voluntary  savings  therefore  reduce  the  risk  of  a  negative  impact 
that gas shortages would have on the competitiveness of industries.  

Therefore,  the  proposed  Council  Recommendation  on  continuing  coordinated  demand-
reduction measures recommends that Member States continue reducing their demand by 15% 
compared to the reference period of 1 April 2017 to 31 March 2022.  

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• 

Consistency with existing policy provisions in the policy area 

The proposed instrument complements existing relevant EU initiatives and legislation, which 
ensure  that  citizens  can  benefit  from  secure  gas  supplies  and  that  customers  are  protected 
against major supply disruptions. It also furthers the objective of diversification of natural gas 
supply.  

It  flows  logically  from  existing  initiatives,  such  as  the  “REPowerEU”,  the  proposal  for  a 
“Hydrogen and Gas Market Decarbonisation Package” and the “Save Gas for a Safe Winter” 
initiative,  including  Regulation  (EU)  2022/1369  on  coordinated  demand-reduction  measures 
for gas, amended by Regulation (EU) 2023/706. The provisions are complementary to the EU 
legislation  on  internal  market  and  security  of  supply,  in  particular  to  Regulation  (EU) 
2017/1938.  It  also  supplements  Council  Regulation  (EU)  2022/2576  enhancing  solidarity 
through  better  coordination  of  gas  purchases,  exchanges  of  gas  across  borders  and  reliable 
price benchmarks. Solidarity mechanisms are in place, ensuring that Member States cooperate 
across borders to  ensure that energy is  provided  to  those customers in  a region  who need it 
most, in case of supply disruptions. 

Following the Russian invasion of Ukraine, the EU has set out the REPowerEU Plan with the 
aim to end the EU's dependency on Russian fossil fuels, as soon as possible and at the latest 
by  2027.  To  achieve  this,  REPowerEU  sets  out  a  plan  to  diversify  energy  supplies,  save 
energy and accelerate the green transition. The proposed initiative is fully consistent with the 
goals  set  out  in  REPowerEU.  This  proposal  for  a  Council  Recommendation  is  therefore 
complementary  to  existing  provisions  and  the  recent  initiatives  in  the  energy  sector, 
safeguarding the security of gas supply, helping to stabilise the market and keeping the prices 
in check, and contributing to saving energy. 

The “Save Gas for a Safe Winter” Communication adopted on 20 July 2022 sets out the tools 
that the EU already has available for a coordinated demand reduction, and what else needs to 
be  done,  so  that  the  EU  is  ready  for  full  or  partial  disruptions.  The  proposed  initiative 
responds  to  the  increased  risks  resulting  from  Russia’s  war  against  Ukraine  and  is  fully 
complementary to the existing security of supply rules. 

• 

Consistency with other Union policies 

.  This  proposal  for  a  Council  Recommendation  is  consistent  other  initiatives  aiming  to 
improve the Union’s energy resilience and to prepare for possible emergency situations and is 
fully  compatible  with  competition  and  market  rules,  as  functioning  cross-border  energy 
markets  are  key  to  ensure  security  of  supply  in  a  situation  of  supply  shortages. 
Recommending  more  coordinated  demand  reductions  is  also  in  line  with  the  Commission’s 
Green Deal and Fit-for-55 objectives. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

The Recommendation which contributes to security of energy supply is to be adopted on the 
basis of Article 194(2) TFEU together with Article 292 TFEU. Article 292 provides the legal 
basis for the Council to adopt  recommendations based on a proposal  from  the Commission. 
The  initiative  does  not  propose  any  extension  of  EU  regulatory  power  or  binding 
commitments  on  Member  States.  It  is  the  Member  States  who  will  decide,  based  on  their 
national  circumstances,  how  they  implement  this  Council  recommendation.  In  the  field  of 
energy, the EU has a shared competence pursuant to Article 4 (2) (i) TFEU. 

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Regulation (EU) 2022/1369, amended by Regulation (EU) 2023/706, established the rules for 
coordinated  demand-reduction  measures  and  set  a  15%  demand  reduction  target,  based  on 
Article 122(1) TFEU. Regulation (EU) 2022/1369 expires on 31 March 2024.  

This  proposed  Council  Recommendation  recommends  that  Member  States  continue  their 
efforts  of  reducing  gas  demand,  in  the  same  spirit  of  solidarity  as  showcased  while 
implementing Regulation (EU) 2022/1369. 

• 

Subsidiarity (for non-exclusive competence)  

The  measures  planned  to  be  continued  under  the  present  initiative  are  fully  in  line  with  the 
subsidiarity  principle.  Because  of  the  scale  and  the  significant  effect  of  further  cuts  in  gas 
supply  on  the  part  of  Russia,  there  is  a  need  for  coordinated  action  by  Member  States.  A 
continued  coordinated  approach  through  Union-wide  demand  reduction,  in  the  spirit  of 
solidarity, is necessary to minimise the risk of potential major disruptions during winter 2024-
2025 when gas consumption will be higher and where Member States will need to partly rely 
on the gas stored during the injection season.  

Given the unprecedented nature of the gas supply crisis and its transboundary effects, as well 
as the level of integration of the EU internal energy market, action at Union level continues to 
be  warranted  as  Member  States  alone  cannot  sufficiently  effectively  address  the  risk  of 
serious economic difficulties resulting from price hikes or significant supply disruptions in a 
coordinated  manner.  Only  continued  EU  action  motivated  by  a  spirit  of  solidarity  between 
Member States can ensure that supply disruptions do not lead to lasting harm for citizens and 
the economy. 

By reason of its scale and effects, the measure can be better achieved at Union level, hence 
the Union may adopt measures, in accordance with the principle of subsidiarity as set out in 
Article 5 of the Treaty on European Union. 

• 

Proportionality 

The  initiative  complies  with  the  proportionality  principle.  The  policy  intervention  is 
proportional to the dimension and nature of the problems defined and the achievement of the 
set objectives.  

In view of the unprecedented geopolitical situation and the  remaining threat for citizens and 
the EU economy, there is a clear need for continued coordinated action. Hence, the proposal 
does  not  go  beyond  what  is  necessary  to  achieve  the  objectives  laid  down  in  the  current 
instrument.  The  measures  proposed  to  be  recommended  are  considered  proportionate  and 
build  to  the  extent  possible  on  existing  approaches,  such  as  the  existing  crisis  levels  and 
emergency  plans  established  in  accordance  with  Regulation  (EU)  2017/1938  and  the 
provisions of Regulation (EU) 2022/1369 which are set to expire on 31 March 2024.  

This  proposal  sets  the  final  result  that  is  recommended  to  be  achieved,  in  the  form  of  a 
voluntary gas reduction target for Member States, while giving Member States full autonomy 
in  choosing  the  most  effective  means  to  meet  such  a  voluntary  target  according  to  their 
national specificities and the measures already foreseen in the national emergency plans. 

• 

Choice of the instrument 

To  achieve  the  objectives  referred  to  above,  the  TFEU  provides  for  the  adoption  by  the 
Council of Recommendations notably in its Article 292 together with Article 194(2) TFEU, 

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based  on  a  proposal  from  the  Commission.  A  Council  Recommendation  is  an  appropriate 
instrument in this case, considering that it recommends continuing the coordinated demand-
reduction  set  out  in  Regulation  (EU)  2022/1369,  amended  by  Regulation  (EU)  2023/706, 
while nevertheless recognising that a legally binding reduction of demand is at this moment in 
time  no  longer  necessary.  As  a  legal  act,  albeit  one  of  a  non-binding  nature,  a  Council 
recommendation  signals  the  commitment  of  Member  States  to  the  measures  included  and 
provides a strong political basis for cooperation in these areas, while fully respecting Member 
State competences.  

3. 

• 

RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER 
CONSULTATIONS AND IMPACT ASSESSMENTS 

Stakeholder consultations 

Due to the politically sensitive nature of the proposal and urgency to prepare the proposal so 
that  it  can  be  adopted  on  time  by  the  Council  before  the  expiration  of  Regulation  (EU) 
2022/1369  by  31  March  2024,  a  specific  stakeholder  consultation  could  not  be  carried  out. 
However,  lessons  learned  through  applying  Regulation  (EU)  2022/1369  and  reviewing  that 
Regulation  via  Report  COM(2023)  173  and  Report  COM(2024)  88  have  been  taken  into 
account.  Regular  exchanges  with  Member  States  and  stakeholders  have  taken  place  via, 
among others, the Gas Coordination Group on the application of Regulation (EU) 2022/1369, 
since its entry into force on 8 August 2022.  

• 

Fundamental rights 

No  negative  impact  has  been  identified  on  fundamental  rights.  The  measures  under  this 
instrument  will  not  affect  the  rights  of  customers  who  are  categorised  as  protected  under 
Regulation (EU) 2017/1938, including all household customers. The instrument will enable to 
reduce the risks associated with gas shortage that would otherwise have major implications on 
the economy and society. 

4. 

BUDGETARY IMPLICATIONS 

This proposal does not require additional resources from the EU budget. 

• 

Detailed explanation of the specific provisions of the proposal 

This proposal for a Council Recommendation proposes to recommend the following: 

• 

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1 

Continue ongoing demand-reduction measures by Member States in order to achieve 
a 15% gas demand reduction compared to the reference years of April 2017 – March 
2022 until parts of Directive (EU) 2023/1791 of the European Parliament and of the 
Council1 are transposed by 11 October 2025.  

Encourages  Member  States  to  continue  their  current  demand  reduction  reporting  to 
Eurostat, including a breakdown per sector.  

Directive  (EU)  2023/1791  of  the  European  Parliament  and  of  the  Council  of  13 September  2023  on 
energy  efficiency  and  amending  Regulation  (EU) 2023/955   (OJ  L  231,  20.9.2023,  p.  1, 
ELI:  http://data.europa.eu/eli/dir/2023/1791/oj). 

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2024/0054 (NLE) 

Proposal for a 

COUNCIL RECOMMENDATION 

on continuing coordinated demand-reduction measures for gas 

THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 292 in conjunction with Article 194(2) thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

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This proposal for a Council Recommendation aims at continuing the ongoing demand-
reduction measures by Member States in order to achieve a 15% gas demand reduction 
compared  to  the  reference  years  of  April  2017  –  March  2022.  Its  purpose  is  also  to 
encourage  Member  States  to  continue  their  current  demand  reduction  reporting  to 
Eurostat, including a breakdown per sector. 
Council Regulation (EU) 2022/1369 (2) was adopted in view of the gas supply crisis 
caused  by  Russia’s  invasion  of  Ukraine.  It  aims  at  voluntarily,  and,  if  necessary, 
mandatorily reducing the Union’s gas demand, facilitating the filling of storages and 
ensuring  better  preparation  against  any  further  supply  disruptions.  It  was  adopted  in 
view of the imminent need for the Union to react with temporary measures in a spirit 
of solidarity between Member States. 

Pursuant to Regulation (EU) 2022/1369, Member States were to use their best efforts 
to reduce their gas consumption by 15 %, firstly in the period from 1 August 2022 to 
31  March  2023,  and,  after  Council  Regulation  (EU)  2023/7063  extended  its 
application, in the period from 1 April 2023 and 31 March 2024. Should the voluntary 
demand-reduction measures prove to be insufficient in addressing the risk of a serious 
supply  shortage,  the  Council,  acting  on  a  proposal  from  the  Commission,  was 
empowered  to  declare  a  Union  alert,  which  would  trigger  a  mandatory  demand-
reduction obligation. Member States adopted measures  to reduce their respective gas 
demand in a spirit of solidarity that resulted in effective gas demand reductions across 
the Union of more than 15 %, from August 2022 to December 2023. 

Pursuant to Article 9 of Regulation (EU) 2022/1369, the Commission has to carry out 
a new review of this Regulation by 1 March 2024, in view of the general situation of 
gas supply to the Union and present a report on the main findings to the Council. The 
Commission presented the main findings of its review in its Report COM(2024) 88. 

Council Regulation (EU) 2022/1369 of 5 August 2022 on coordinated demand-reduction measures for 
gas (OJ L 206, 8.8.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/1369/oj). 
Council Regulation (EU) 2023/706 of 30 March 2023 amending Regulation (EU) 2022/1369 as regards 
prolonging  the  demand-reduction  period  for  demand-reduction  measures  for  gas  and  reinforcing  the 
1, 
reporting 
ELI: http://data.europa.eu/eli/reg/2023/706/oj). 

and  monitoring 

implementation 

31.3.2023, 

(OJ  L 

their 

93, 

of 

p. 

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(5) 

(6) 

(7) 

(8) 

In its Report COM(2024) 88 the Commission concluded that, although the gas security 
of  supply  situation  has  improved  thanks  to  targeted  investments  and  a  number  of 
measures,  including  demand  reduction  by  Regulation  (EU)  2022/1369,  the  general 
security of supply situation remains delicate. The global gas market remains tight and 
no  significant  improvements  in  global  liquefaction  capacities  are  expected  before 
2025-2027, while other downside risks remain that can deteriorate the current security 
of  supply  situation.  It  also  concluded  that  demand  reduction  has  significantly 
contributed to the phase out of circa 65 billion cubic meters (bcm) of Russian gas in 
2023,  primarily  in  the  households  and  industries  sectors.  In  2023,  demand  reduction 
has  been  pivotal  to  end  the  winter  with  adequate  storage  levels  and  to  provide  the 
necessary  flexibility  in  summer  in  order  to  meet  the  90%  storage  obligation  set  by 
Regulation (EU) 2017/1938 of the European Parliament and of the Council 4. 

Recent  episodes  of  significant  price  volatility  including  during  the  summer  and 
autumn of 2023, when prices increased by more than 50 % within a few weeks, caused 
by events such as the strike in Australian liquefied natural gas (LNG) facilities and the 
disruption of the Balticconnector, show that markets remain fragile and susceptible to 
even  relatively  minor  shocks  regarding  the  demand  and  supply.  Under  such 
conditions,  the  fear  that  supply  of  natural  gas  would  become  scarce  may  trigger 
negative  systemic  reactions  across  the  Union  with  serious  repercussions  on  energy 
prices.  Furthermore,  due  to  the  significant  decrease  in  Russian  pipeline  gas  imports 
over  the  past  year,  the  availability  of  overall  gas  supplies  to  the  Union  has 
considerably decreased as compared to pre-crisis conditions. The Union has received 
approximately  25  bcm  of  Russian  gas  via  pipelines  and  overall,  Russian  supplies 
accounted  for  only  15%  of  the  Union’s  total  imports  (pipeline  and  LNG)  in  2023, 
compared to 45% in 2021. 

Due  to  the  remaining  tight  supply  and  demand  balance,  gas  supply  disruptions  can 
have  a  sizable  impact  on  the  gas  and  electricity  prices  and  could  cause  harm  to  the 
economy  of  the  Union,  by  affecting  its  competitiveness,  and  negatively  impact 
European  citizens.  To  that  end,  continued  coordinated  demand  reduction  by  all 
Member States in a spirit of solidarity is recommended, among others to refill storage 
capacities  in  an  efficient  way  and  with  minimum  market  disturbances,  which 
contributes to  ensuring the security of gas supply ahead of the  winter of 2024-2025. 
Proactive, coordinated and voluntary savings reduce the risk of a negative impact that 
gas shortages would have on the competitiveness of industries. 

Since the entry into force of Regulation (EU) 2022/1369, the level of preparedness in 
the  gas  market  and  the  Union’s  security  of  supply  have  considerably  improved. 
However, risks persist for the Union’s security of energy supply as the global situation 
on  the  gas  market  remains  tight  and  as  prices  are  still  higher  than  pre-crisis.  This  is 
exacerbated  by  market  volatility  stemming  inter  alia  from  tense  geopolitical 
circumstances, currently illustrated by, among others, the crisis in the Middle East and 
the  Red  Sea.  Due  to  the  supply  disruptions  and  the  tightness  experienced  in  past 
months on the market, twelve Member States are still in the first or second crisis level 
pursuant  to  the  common  EU  classification,  as  set  out  by  Article  11(1)  of  Regulation 
(EU) 2017/1938. 

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Regulation  (EU)  2017/1938  of  the  European  Parliament  and  of  the  Council  of  25  October  2017 
concerning  measures  to  safeguard  the  security  of  gas  supply  and  repealing  Regulation  (EU)  No 
994/2010 OJ L 280, 28.10.2017, p. 1, ELI: http://data.europa.eu/eli/reg/2017/1938/oj). 

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(9) 

These possible difficulties for security of supply risk are exacerbated by a number of 
additional risks, including an end to the current gas transit agreement through Ukraine 
by 31 December 2024, through which ca. 14 bcm transited in 2023. Other risks are a 
possible rebound in Asian LNG demand that would reduce the availability of gas on 
the global gas market, a cold winter 2024-2025 that could lead to  an increase of gas 
demand of up to 30 bcm, extreme weather events potentially affecting the hydropower 
storage and nuclear production due to low water levels, and the subsequent increase in 
demand  for  gas-fired  power  generation.  Additional  risks  result  from  further 
disruptions  of  critical  infrastructures,  such  as  experienced  with  the  acts  of  sabotage 
against  the  Nord  Stream  pipelines  in  September  2022  or  the  disruption  of  the 
Balticconnector  pipeline  in  October  2023,  and  from  the  deterioration  of  the 
geopolitical  environment,  in  particular  in  countries  and  regions  relevant  to  Union 
energy security of supply, such as Ukraine and the Middle East. 

(10)  Global gas markets remain tight and are expected to remain so for a certain period of 
time.  As  noted  by  the  International  Energy  Agency  (IEA)  in  its  Medium-Term  Gas 
Report 20235, global LNG supply grew only modestly in 2022 (by 4 %) and in 2023 
(by 3 %).  In its  World  Energy Outlook  20236, the  IEA  expects  that market  balances 
will  remain  precarious  in  the  immediate  future  until  new  LNG  capacities  are  set  to 
come online in the period 2025-2027. 

(11)  The recently adopted Directive (EU) 2023/1791 of the European Parliament and of the 
Council7  and  Directive  (EU)  2023/2413  of  the  European  Parliament  and  of  the 
Council8 will help to achieve the EU’s decarbonisation goals and to structurally reduce 
demand in the near future, in line with the COP28 Global Stocktake9 which recognises 
the need to transition away from fossil fuels in the energy systems, in a just, orderly 
and  equitable  manner.  Although  the  measures  that  Member  States  will  adopt  to 
transpose those Directives will largely not yet be in force during the application of this 
Recommendation,  they  will  contribute  to  a  gas  demand  reduction  in  the  years  after 
transposition. Considering that important measures of the above- mentioned directives 
will  only  have  to  be  transposed  in  May  2025,  it  is  appropriate  to  recommend  gas 
demand reduction for the transitional period until this transposition.  

(12)  Demand-reduction  by  Member  States  can  contribute  notably  to  the  filling  of 
underground storage facilities, to ensure adequate levels of security of supply for the 
winter  2024-2025  and  to  avoid  perpetuating  shortage  in  storage  filling  to  the  winter 
2025-2026. Continuing to reduce gas demand will also help keep downward pressure 
on prices, to the benefit of the Union consumers and industrial competitiveness. 

(13)  The  recommendation  to  save  gas  should  not  affect  the  need  to  adhere  to  Member 
States’  decarbonisation  objectives.  This  Recommendation  therefore  should  not 

5 

6 

7 

8 

9 

Medium-Term Gas Report 2023 – Analysis – IEA. 

World Energy Outlook 2023 – Analysis – IEA. 

Directive  (EU)  2023/1791  of  the  European  Parliament  and  of  the  Council  of  13 September  2023  on 
energy  efficiency  and  amending  Regulation  (EU) 2023/955   (OJ  L  231,  20.9.2023,  p.  1, 
ELI:  http://data.europa.eu/eli/dir/2023/1791/oj). 
Directive (EU) 2023/2413 of the European Parliament and of the Council of 18 October 2023 amending 
Directive  (EU) 2018/2001,  Regulation  (EU) 2018/1999  and  Directive 98/70/EC  as  regards  the 
promotion  of  energy  from  renewable  sources,  and  repealing  Council  Directive  (EU) 2015/652  (OJ  L 
2023/2413, 31.10.2023, ELI: http://data.europa.eu/eli/dir/2023/2413/oj). 
UNFCCC Global Stocktake, https://unfccc.int/sites/default/files/resource/cma2023_L17_adv.pdf 

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disincentivise Member States to continue to switch from coal to gas for e.g. electricity 
generation in case this helps Member States achieve their decarbonisation objectives, 
as  set  out  in  their  integrated  national  energy  and  climate  plans,  established  under 
Regulation (EU) 2018/1999 of the European Parliament and of the Council10.  

(14)  The  demand-reduction  provisions  of  this  Recommendation  acknowledge  specific 
national  circumstances.  Member  States  should  be  able  to  temporarily  limit  the 
recommended  demand  reduction  target  in  case  of  such  national  specificities,  among 
others, where  a Member State faces  an electricity crisis,  as  referred to  in Regulation 
(EU)  2019/941  of  the  European  Parliament  and  of  the  Council  (11).  Such  a  scenario 
could  include  a  limitation  proportional  to  a  significantly  increased  use  of  gas  for 
power  generation,  required  to  export  significantly  more  electricity  to  a  neighbouring 
Member State, due to exceptional circumstances, such as low hydropower or nuclear 
availability  in  the  Member  State  concerned,  or  in  the  neighbouring  Member  State  to 
which significantly more electricity is exported. 

HAS ADOPTED THIS RECOMMENDATION:  

(1) 

(2) 

(3) 

(4) 

10 

11 

Member States should address a situation of difficulties in the supply of gas, with a 
view to safeguarding Union security of gas supply, in a spirit of solidarity, through 
improved  coordination,  monitoring  of  and  reporting  on  national  gas  demand-
reduction. 

Member States should use their best efforts to reduce their gas consumption over the 
period from 1 April 2024 to 31 March 2025 (the ‘reduction period’) at least by 15 % 
compared  to  their  average  gas  consumption  in  the  ‘reference  period’  from  1  April 
2017 to 31 March 2022.  

For  the  purpose  of  reducing  gas  consumption  in  each  Member  State  over  the 
‘reduction period’, gas demand should be 15 % lower compared to its reference gas 
consumption.  ‘Reference gas consumption’ means the volume of a Member State’s 
average gas consumption during the reference period. For Member States where gas 
consumption increased at least by 8 % in the period from 1 April 2021 to 31 March 
2022  compared  to  the  average  gas  consumption  during  the  reference  period, 
‘reference  gas  consumption’  means  only  the  volume  of  gas  consumption  in  the 
period from 1 April 2021 to 31 March 2022. 

This Recommendation is not addressed to a Member State whose electricity system 
is synchronised only  with the electricity system  of a third country in the event it is 
desynchronised from that third country's system for as long as isolated power system 
services or other services to the power transmission system operator are required to 
ensure the safe and reliable operation of the power system. 

Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the 
Governance  of  the  Energy  Union  and  Climate  Action,  amending  Regulations  (EC)  No  663/2009  and 
(EC)  No  715/2009  of  the  European  Parliament  and  of  the  Council,  Directives  94/22/EC,  98/70/EC, 
2009/31/EC,  2009/73/EC,  2010/31/EU, 2012/27/EU  and  2013/30/EU of  the  European  Parliament  and 
of the Council, Council Directives 2009/119/EC and (EU) 2015/652 and repealing Regulation (EU) No 
525/2013  of  the  European  Parliament  and  of  the  Council  (OJ  L  328,  21.12.2018,  p.  1, 
ELI: http://data.europa.eu/eli/reg/2018/1999/oj). 
Regulation  (EU)  2019/941  of  the  European  Parliament  and  of  the  Council  of  5  June  2019  on  risk-
preparedness in the electricity sector and repealing Directive 2005/89/EC (OJ L 158, 14.6.2019, p. 1). 

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(5) 

(6) 

(7) 

(8) 

(9) 

This  Recommendation  is  not  addressed  to  a  Member State  for  as  long  as  that 
Member State  is  not  directly  interconnected  to  a  gas  interconnected  system  of  any 
other Member State. 

A Member State should have the option to limit the reference gas consumption used 
for calculation of the demand-reduction target pursuant to point 3 by the volume of 
gas equal to the difference between its intermediate target  for 1 August 2022 set by 
Annex  1a  of  Regulation  (EU)  2022/1032  and  the  actual  volume  of  stored  gas 
on 1 August 2022, if it fulfilled the intermediate target on that date. 

A Member State should have the option to limit the reference gas consumption used 
for calculation of the demand-reduction target pursuant to point 3 by the volume of 
gas  consumed  during  the  reference  period  as  feedstock.  ‘Feedstock’  means  ‘non-
energy  use  of  natural  gas’  as  referred  to  in  energy  balances  calculations  by  the 
Commission (Eurostat). 

A Member State should also be able to adjust the reference gas consumption used to 
calculate the demand-reduction target pursuant to point 3 by the volume of increased 
gas consumption resulting from the switch from coal to gas used for district heating, 
if that increase is of at least 8 % in the period from 1 August 2023 to 31 March 2024 
compared  to  the  average  gas  consumption  during  the  reference  period  and  to  the 
extent that this increase is directly attributable to the switch. 

A  Member State  should  have  the  option  to  limit  the  demand  reduction  target  by 8 
percentage points, if its interconnection with other Member States measured in firm 
technical  export  capacity  compared  to  its  yearly  gas  consumption  in 2021  is 
below 50 % and that capacity on interconnectors to other Member States has in fact 
been used for the transport of gas at a level of at least 90 %  in the preceding month , 
unless  the  Member State  can  show  there  was  no  demand  and  the  capacity  was 
maximised,  and  that  its  domestic  LNG  facilities  are  commercially  and  technically 
ready  to  re-direct  gas  to  other  Member States  up  to  the  volumes  required  by  the 
market. 

(10) 

A Member State should be able to temporarily limit any demand reduction targets in 
the case of an electricity crisis to mitigate the risk for electricity supply, especially if 
there  are  no  economic  alternatives  to  replace  the  gas  necessary  for  producing 
that  case, 
electricity  without  seriously  endangering  security  of  supply.  In 
the Member State is recommended to inform the reasons for the limitation. 

(11) 

The measures chosen by Member States to reduce demand should be clearly defined, 
transparent, proportionate, non-discriminatory and verifiable.  

(12)  When  taking  measures  affecting  customers,  other  than  protected  customers  as 
defined  in  Article  2,  point  5,  of  Regulation  (EU)  2017/1938,  Member  States  are 
recommended  to  follow  objective  and  transparent  criteria  which  take  into  account 
their economic importance as well as, among others, the following elements:  

(a) 

(b) 

(c) 

(d) 

the impact of a disruption on supply chains that are critical for society;  

the possible negative impacts in other Member States, in particular on supply 
chains of downstream sectors that are critical for society;  

the potential long-lasting damage to industrial installations;  

the  possibilities  for  reducing  consumption  and  substituting  products  in  the 
Union. 

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(13)  When decided on measures to save gas, Member States are recommended to consider 
measures  to  reduce  gas  consumed  in  the  electricity  sector,  measures  to  encourage 
fuel  switch  in  the  industry,  national  awareness-raising  campaigns,  and  targeted 
obligations  to  reduce  heating  and  cooling,  to  promote  switching  to  renewable  fuels 
and reduce consumption by industry when deciding on demand-reduction measures. 

(14)  Member  States  are  recommended  to  inform  the  Commission  of  new  demand-
reduction measures not yet notified to the Commission pursuant to Regulation (EU) 
2022/1369.  

(15)  Member  States  are  recommended  to  monitor  the  implementation  of  the  demand-
reduction measures on their territory and Member States are recommended to report 
on their gas consumption (in terajoules, TJ) to the Commission via Eurostat at least 
every two months and not later than by the 15th day of the following month. 

(16) 

It  is  recommended  that  reporting  to  Eurostat  includes  a  breakdown  of  gas 
consumption per sector, including gas consumption for the following sectors: 

(a) 

gas input for electricity and heat generation; 

(b)  gas consumption in industry; 

(c) 

gas consumption in households and services. 

(17) 

(18) 

For  the  purpose  of  the  recommendation  in  this  point,  the  definitions  and  statistical 
conventions established in Regulation (EC) 1099/200812 of the European Parliament 
and of the Council should be considered relevant. 

It  is  welcomed  that  the  Commission  supports  the  implementation  of  this 
recommendation  by  monitoring  demand-reduction  achieved  per  sector  and  the 
demand-reduction measures taken, together with the Gas Coordination Group.  

Done at Brussels, 

For the Council 
The President 

12 

Regulation (EC) No 1099/2008 of the European Parliament and of the Council of 22 October 2008 on 
energy statistics (OJ L 304, 14.11.2008, p. 1, ELI: http://data.europa.eu/eli/reg/2008/1099/oj). 

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