Prohibition of reloading of Russian LNG in a context of transshipment as of March 27^th 2025

Council regulation (EU) 2024/1745 of 24 June 2024 amended Regulation (EU) nr. 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine by amongst other introducing a new Article 3r, §1:

“It shall be prohibited to provide reloading services in the territory of the Union for the purposes of transshipment operations of LNG falling under code 2711 11 00, originating in Russia or exported from Russia”.

The same regulation foresees an exemption for bunkering and the possible derogation for reloading of LNG of Russian origin for its transport to another EU Member State (article 3r, §3) when such Member State has confirmed that the transshipment is used to ensure its energy supply.

The Royal Decree of 18 March 2025 concerning restrictive measures on the transshipment of Russian LNG in view of Russia's actions destabilizing the situation in Ukraine details the implementation of the EU sanction in Belgium by defining rules and procedures applicable to the Terminal Users, the Terminal Operator (Fluxys LNG) and the Belgian Competent Authorities. This Royal Decree entered into force on 25 March 2025 (but only applies as of 27 March 2025 with respect to contracts concluded before 25 June 2024).

This EU sanction and its implementing measures apply as of 27^th of March 2025 to all Terminal Users and imply new processes and requirements summarised below (Fig.1).

Fig.1. Overview of the implementation of the 14^th EU Sanctions Package at the Zeebrugge LNG Terminal

1. Unloading - Declaration of LNG Origin

The Terminal User shall send a Declaration of the LNG Origin no later than 4 calendar days prior to the start of the operation.

Without any declaration or if the declaration is considered as being not complete or not valid, the Terminal Operator will consider the LNG as ‘Unidentified LNG’ and will treat it as Russian LNG.

2. Energy Balancing System

The Terminal Operator implemented an Energy (mass) Balancing System implying the segregation of incoming LNG origin. The Gas In Storage (GIS) inventory of every Terminal Users is divided in two sub-inventories according to the LNG origin: ‘Russian or Unidentified LNG’ and ‘Non-Russian LNG’.

Every Terminal User has to define via the new GSmart portal which LNG Origin Priority shall be given to the LNG leaving its Gas In Storage inventory, per service categories: Send-Out, Truck Loadings and deals on the Commodity Transfer Point.

3. Loading - Loading Request Form and EU Member State Attestation

The Terminal User shall send a Loading Request Form no later than 4 calendar days prior to the start of the operation.

In case of reloading (even partially) of ‘Russian or Unidentified LNG’ to another EU Member State, this Loading Request Form and the EU Member State Attestation shall be sent no later than 7 calendar days prior to the start of the loading operation.

If the Loading Request Form or the EU Member State Attestation is not valid/complete or not received within the required timeframe, the operation will be cancelled, and the ship will not be authorised to enter the port of Zeebrugge.

Practical Details

All practical details related to the new processes and requirements are described in the Terminal User Guide and have been summarized in the dedicated info-session given to the Terminal Users on 25 February 2025.

Feel free to contact your Key Account Manager or send your questions to info.lng@fluxys.com.