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
Date: 2025-06-17
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy policy, Russia, energy diversification, energy efficiency, energy supply, import (EU), import restriction, natural gas, security of supply, self-sufficiency in energy

EN 

  EN 

   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}  
 
 
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  REPowerEU1  plan,  and  the  significant  progress  made 
within three years to diversify away from Russian energy by implementing REPowerEU2, 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 
IEA4: “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 
the  fuel  mix, 
regions, 
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 

increased  strategic  gas  stocks,  diversification  of 

including 

1 COM(2025) 440 final. 
2 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 

 
 
 
Communication for an energy policy for Europe5 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 COM(2007) 1 final. https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2007:0001:FIN:EN:PDF  
6 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 

 
 
 
 
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  review10,  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 

 
 
 
 
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 
country12,  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 assets13.  

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 hubs14 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 

 
 
 
 
 
 
 
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 

 
 
 
 
 
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 

 
 
 
  
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 

 
 
 
 
 
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  enrichment17 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 

 
 
 
 
 
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 

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 

02040608010012014016004/01/202104/02/202104/03/202104/04/202104/05/202104/06/202104/07/202104/08/202104/09/202104/10/202104/11/202104/12/202104/01/202204/02/202204/03/202204/04/202204/05/202204/06/202204/07/202204/08/202204/09/202204/10/202204/11/202204/12/2022$/barrelRussia's invasion of Ukraine 
 
 
 
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 suppliers18. 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  202420,  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 

 
 
 
 
Coordination Group21 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 Commission and Member States confirm no gas supply concerns in the New Year - European Commission 
22 Europe’s Rising Gas-Hedging Costs Show Supply Fears Persist - Bloomberg 

11 

 
 
 
 
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%
30%
20%
10%
0%

W
G

68%

62%

42%42%41%39%

42%

24%

20%

3%

34%

29%

20%

2,0 

2,2 

2,1 

2,3 

1,9 

1,0 

0
4
4
-
R
E
V
V

0
4
4
-
R
E
V
V

0
4
4
-
R
E
V
V

0
0
0
1
-
R
E
V
V

0
4
4
-
R
E
V
V

0
0
0
1
-
R
E
V
V

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 countries24, 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 

23 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.  

12 

 
 
 
 
 
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 tSW25) 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 

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 

23%27%38%29%55%77%45%7%0%10%20%30%40%50%60%70%80%90%100%Uranium miningConversionEnrichmentOtherEURussia 
 
 
 
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 

26 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 

14 

 
 
 
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 imports32 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 This share has further dropped in 2025 since Czechia stopped importing from Russia in April. 
32 According to COMEXT information from 2024 and 2023. 

15 

 
 
 
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 MOL Group Integrated Annual report 2024. 
34 IEA (January 2025) “Gas Market Report, Q1-2025” 

16 

 
 
 
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 Agency36  
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, 

35 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 

17 

 
 
 
 
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 

 
 
 
  
 
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-GIE38 

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 

 
 
 
 
 
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 

Description 

The Slovakia – Hungary Gas Interconnection  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 

Southern Gas Corridor, including Trans 
Anatolia Natural Gas Pipeline (TANAP) and 
the Trans-Adriatic Pipeline (TAP) 

20 

 
 
  
 
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 

supply 

improving 

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, 
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 
regional  gas 
towards  Hungary,  expanding 

21 

 
 
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 
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 

large-scale 

The gas infrastructure in the EU is  sufficiently developed, well-interconnected and flexible, 
to  enable  Member  States40  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 Non-PCI priority project completed in the framework of the CESEC High-Level Group 
40 except Cyprus and Malta. 

22 

 
 
 
 
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 Groups42 
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 

Technical details 

Expansion of the Krk FSRU terminal in Croatia   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.  

infrastructure 

reinforcements 

Transmission 
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. 

technical  capacity  from  Croatia 

Current 
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 REPowerEU Plan, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022DC0230 
42 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  

23 

 
 
 
 
 
 
 
 
The  Adriatica  Line  and  Poggio  Renatico 
compressor station to remove existing bottleneck 
within the Italian gas network 

The  supported  projects  will  increase  transport 
capacity  along  the  south-north  route  from  the 
entry  points  located  in  southern  Italy  from  126 
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 
supported  projects  are 
completed by 2026, the capacity will reach up to 
14,6 bcm/y.  

the 

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  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  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 corridors44:   

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 points46 
3.  Italy-Austria-Slovakia  via  Tarvisio/Arnoldstein  and  Baumgarten  interconnection 

points47  

  and 

transparency  platform,  https://www.entsog.eu/maps 

43  ENTSOG  system  capacity  map  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 

 
 
 
 
 
 
 
 
 
 
  
 
 
4.  Italy-Austria-Hungary 

via 

Tarvisio/Arnoldstein 

and  Mosonmagyaróvár 

interconnection points48 

5.  Croatia-Hungary via Dravaszerdahely interconnection point49 
6.  Greece-Bulgaria-Romania-Hungary  via  Kulata/Sidirokastron,  Stara  Zagora  (IGB), 

Negru Voda/Kardam, Csanadpalota interconnection points50 

7.  Germany-Czechia-Slovakia via VIP Brandov and Lanžhot interconnection points51  
8.  Germany-Austria-Slovakia  via  VIP  Oberkappel  and  Baumgarten  interconnection 

points52 

9.  Germany-Austria-Hungary 
interconnection points53 

via  VIP  Oberkappel 

and  Mosonmagyaróvár 

10. Germany-Poland-Slovakia  via  Mallnow,  GCP  GAZ-SYSTEM/ONTRAS  and Vyrava 

interconnection points54 

11. 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 points55  

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 

 
 
 
 
 
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/  

26 

 
 
 
 
 
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 
points57. 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 users58. 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 infrastructure62.  

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. 

27 

 
 
 
 
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 

28 

 
 
 
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  markets63.  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.  

63 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 

29 

 
 
 
 
Furthermore,  in  the  2024  edition  of  the  Union-wide  security  of  supply  simulation65  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 cases66 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 Security of Supply Simulation | ENTSOG 
66 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”. 

30 

 
 
 
 
 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 Institute for Energy Economics and Financial Analysis: Global LNG Outlook 2024-2028 (April 2024). 
68 European Gas Long-Term Forecast Quarterly Update, March 2025 
69 Global LNG Market Outlook 2030: Focus on Supply Risks | Insights | Bloomberg Professional Services 

31 

 
 
 
 
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.  

32 

 
 
 
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. 

33 

 
 
 
 
long-term  contracts)  when  the  benefits  of  the  larger  LNG  supply  globally71  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. 

34 

 
 
 
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 estimates73 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 see, for example, Modelling based gas market analysis 2023/24 - REKK 
74  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 

 
 
 
 
 
 
 
 
 
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%. 

36 

 
 
 
 
 
 
 
 
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. 

37 

 
 
 
 
 
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.  

to  develop  comprehensive  national 
Additionally,  Member  States  will  be  required 
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.  

38 

 
 
 
 
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.  

39 

 
 
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 concerns76.  

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 Plans77.  

76 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).  
77 Slovakian plan:  MINISTERSTVO HOSPODÁRSTVA SLOVENSKEJ REPUBLIKY 

40 

 
 
 
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 
202678 as already done by several other countries that used to import Russian oil through the 
Druzhba pipeline (Germany, Poland, Czechia).79 

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 

78 integrated-annual-report-2024-eng.pdf 
79 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). 

41 

 
 
 
 
 
 
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 

42 

 
 
 
Source: oil weekly bulletin 

Source: oil weekly bulletin 

Note: Euro-Super 95 

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  

43 

 
 
  
 
 
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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