The European Environmental Bureau (EEB), an NGO, released a report reviewing EU policies, assessing gaps and potential lock-ins for current unsustainable practices in biomethane production.

The EU’s decision to significantly reduce its dependence on Russian gas as a result of the war in Ukraine has strong implications for both domestic biomethane production and bio-LNG import strategies. The EU’s RePowerEU plan (2022) aims to increase annual biomethane production to 35 billion m³ by 2030, primarily through the Biomethane Industrial Partnership (BIP), a coalition of over 175 organisations spanning agriculture, energy, and finance, a volume equivalent to roughly 20 % of the current Russian natural-gas imports.

Scaling up both biomethane and bio-LNG imports (and domestic production) will necessitate investment in infrastructure (upgrading biogas to biomethane, grid injection, LNG terminals, certification and sustainability verification) and careful management of sustainability criteria to ensure these gases genuinely contribute to climate objectives.

The EBB’s report critically examines the European Union’s biogas and biomethane policies. It questions whether current strategies, particularly the RePowerEU plan and the BIP, promote sustainable energy transition or risk environmentally harmful practices. In fact, the report notes: no environmental impact assessment accompanies this massive scale-up. As a result, public and private investments, estimated at over EUR 37 billion, may lock in unsustainable systems.

Veyt provides the report summary below.

The report finds that no EU policy adequately addresses the environmental and social risks of biogas production. Eight key EU policies, including the Renewable Energy Directive (RED III), Waste Framework Directive, and Nitrates Directive, were reviewed against six sustainability impacts: methane leaks, waste management, community effects, industrial livestock incentives, land-use change, and fossil fuel dependence.

None fully addresses these issues. For instance:

RED III counts manure as a zero-emission feedstock, ignoring emissions from livestock farming.

Industrial Emissions Directive excludes cattle farming, leaving a major regulatory gap.

EU Taxonomy and State Aid frameworks classify biogas as sustainable, encouraging investment without full life-cycle analysis.

The report finds a risk of lock-in, too, as EU incentives encourage manure-based biogas, particularly in Germany, the Netherlands, Ireland, and the UK, risking reinforcement of industrial livestock systems. Since manure is treated as an emission-free input, scaling biogas could increase herd sizes, pollution, and land-use pressures, counterproductive to methane reduction efforts.

RePowerEU and related financial mechanisms channel billions toward biogas, fuelled by increasing biomethane demand from the transport sector. Combined with private investments (about EUR 28 billion by 2030), this could accelerate unsustainable expansion. Investors such as Cargill, TotalEnergies, Shell, and Repsol, alongside major utility and meat companies, are heavily engaged, often participating in policy-setting bodies like the BIP, raising concerns about regulatory capture.

Since 2019, manure and agricultural residues have become dominant feedstocks for new biogas plants, displacing energy crops but creating new sustainability issues (see below). If manure-based feedstocks grow, they could increase intensive livestock farming, nitrogen runoff, and water pollution. Conversely, food and energy crops as feedstocks raise food security and biodiversity concerns. Veyt notes, however, that RED III regulates biomethane production in such a way that residue and waste streams are prioritised over food and feed crops as feedstocks. This is to prevent biogas production from competing with food and feed production.

The report concludes that current EU biogas policies risk locking in unsustainable systems. Without regulatory reforms, biogas expansion could increase methane emissions and intensify industrial livestock farming.

Veyt observes that certified feedstocks with lower carbon intensity scores, such as those approved by the International Sustainability and Carbon Certification (ISCC) and Better Biomass, are gaining traction. Demand for high-CI feedstocks like manure is increasing, particularly in countries like the Netherlands and in industries such as the maritime sector, where GHG reduction is considered a key priority. In a separate analysis, we outline the biomethane demand push from the maritime sector in more detail, highlighting at the same time the effect on prices for high-CI feedstock biomethane.