Methane imports and Annex IX – 31 May reporting and proposed EU delays
Swedish importer guide to EU methane Regulation Article 27, Annex IX, 31 May reporting, producer evidence and the proposed 2027–2028 change.
Do you import crude oil, natural gas (including LNG) or coal produced outside the EU? Under Regulation (EU) 2024/1787, Article 27 may require the responsible importer to submit Annex IX information to Sweden’s Environmental Protection Agency (Naturvårdsverket) by 31 May each year. Not every Swedish energy buyer is an importer. A pending proposal to postpone later requirements has not cancelled the current annual reporting duty.
Who is the importer under the Methane Regulation?
Chapter 5 concerns methane emissions from crude oil, natural gas and coal placed on the Union market after production outside the EU. Determine who actually imports the product from a third country and which entity is accountable. An industrial customer buying gas already imported into the internal market is not automatically the Article 27 importer. Naturvårdsverket is Sweden’s receiving authority.
According to the Swedish authority’s guidance, the covered fuels are fossil oil, gas and coal. Bio-oil and refineries are not within this regulation’s listed activity categories. Other sectoral laws may still apply.
Deadlines: law in force versus proposed postponement
| Date or period | Requirement | Status on 11 November 2026 |
|---|---|---|
| 5 May 2025; then 31 May annually | Article 27(1) submission of Annex IX information to the competent authority. | Binding law; not repealed by the pending proposal. |
| 1 January 2027 | Article 28 equivalence of producer-level monitoring, reporting and verification (MRV), with differing contract conditions. | Current legal text, subject to proposed amendment. |
| 1 January 2028 | Proposed postponement of certain import-related MRV obligations. | Proposal and Council negotiating position, NOT enacted law. |
| 5 August 2028 and 5 August 2030 | Later Article 29 methane-intensity reporting and maximum-level obligations. | Dates in current legislation; later commencement also proposed. |
On 14 October 2026 the Commission proposed COM(2026) 569. On 6 November the Council agreed a position proposing MRV obligations from 2028, methane-intensity reports from 2029 and maximum levels from 2031. The procedure 2026/0325(COD) remains open. Check EUR-Lex before changing internal deadlines or contracts.
Annex IX: what information should be collected?
Read Annex IX together with Articles 27–29 and the dates on which individual obligations apply. The groups below are a practical overview, not a substitute for the complete Annex.
| Information group | Supporting material to request | Quality check |
|---|---|---|
| Producer and exporter | Names, addresses, contact details and chain of responsibility. | Is the producer identifiable even when the contract is with an exporter? |
| Origin and route | Country and region of production, transit countries and shipment references. | Does the evidence show origin and route, not only the final seller? |
| Methane data and methods | Relevant producer emissions report, quantitative information and methodology. | Does it cover the correct facility and reporting period? |
| Verification and mitigation | Independent verification, relevant leak detection and repair (LDAR), reporting and standards. | Are report identifiers, methods and verification status real? |
| Contracts and later MRV stages | Contract dates, renewals and producer evidence for Article 28 when applicable. | Was the contract made or renewed before or after 4 August 2024? |
What if the supplier cannot provide complete information?
If Article 27(1) information is missing in whole or in part, the importer must provide sound justification and explain the actual measures taken to obtain it. This is not a general exemption. Retain specific requests, supplier replies, dates, remaining gaps and next actions. Commission guidance cautions that this justification route cannot automatically be applied to later Article 29 obligations.
For Article 28, supply contracts entered into or renewed on or after 4 August 2024 differ from older contracts. Older contracts have a separate obligation to make all reasonable efforts. Document contract dates and supplier relationships, and reassess if an amendment to the Regulation is finally adopted.
Three practical import scenarios
Swedish customer buys gas already imported
A Swedish factory buys natural gas from a supplier inside the EU and does not itself introduce gas from a third country. This fact alone does not make the factory the Article 27 importer. Check actual contracts and market-entry responsibility.
The producer or facility is not identified
An LNG importer knows the exporter but lacks the producer’s identification or verification report. Typing “unknown” into a register is insufficient. Request traceable evidence, document attempts and justify unresolved gaps under the applicable rule.
Supply contract dating from July 2024
A contract signed in July 2024 has not been renewed. Do not treat it as automatically identical to a new or renewed contract after 4 August 2024. Apply Article 28’s special treatment of existing contracts and record reasonable efforts.
Seven steps from supplier request to annual report
- Verify the importer role, product, third-country origin and responsible entity.
- Inventory producers, exporters, contracts, renewals, deliveries and reporting period.
- Request actual Annex IX evidence, including origin, emissions, methods, verification and transport chain.
- Check report IDs, periods, scope, methodology and supplier identities; flag unverifiable information.
- Keep an action log of requests, replies, reminders, sound justifications and owners.
- Draft the annual report against every applicable Annex IX item and current Naturvårdsverket guidance.
- Submit through the authority’s current channel and retain a real receipt, not a simulated acknowledgement.
Frequently asked questions
Do all Swedish energy purchasers have to report?
No. Article 27 applies to the responsible importer of covered crude oil, natural gas or coal from outside the EU. A domestic end-user of already imported energy is not automatically covered as an importer.
What is the annual Annex IX deadline?
The first report was due 5 May 2025; thereafter Article 27(1) generally requires submission by 31 May each year. Check current national submission instructions.
Has Article 28 already been delayed to 2028?
No, not as enacted law on 11 November 2026. The Commission and Council have proposed a postponement, while the current text specifies 1 January 2027.
Can an importer simply write that data are unavailable?
No. Article 27(1) requires sound justification and documentation of real efforts to obtain missing information. This is not an unconditional exemption.
Must an importer hire a particular compliance platform?
No. Commission guidance does not mandate a specific compliance-service provider, but the importer must still provide all legally required evidence.
Related document templates
For practical documentation, a topic-specific template pack is available: Methane import 2026/2027 – Annex IX, annual report and supplier template | Word/PDF/Excel The templates are optional working aids; this guide is useful independently of any purchase.
Official sources and editorial review
- Regulation (EU) 2024/1787, Articles 27–29 and Annex IX
- Swedish Environmental Protection Agency – methane emissions
- European Commission – importer guidance, September 2026
- Council – negotiating position of 6 November 2026
- European Parliament – pending procedure 2026/0325(COD)
Editorial check against EU law, the Swedish Environmental Protection Agency, Commission guidance and the Council’s position on 11 November 2026. This is general information, not individual legal advice, methane measurement, verification or regulatory approval. Recheck legal status before any deadline decision.
