Methane import 2026/2027 – Annex IX, annual report and supplier template | Word/PDF/Excel

Does your company import crude oil, natural gas, LNG or coal produced outside the EU? The methane regulation (EU) 2024/1787 contains concrete information and reporting requirements for companies that are actually importers. This niche document package helps a Swedish company assess its importer role, request information from the supply chain, compile Annex IX information and document deficiencies before annual reporting.

Read the guide: Methane imports and Annex IX – 31 May reporting and proposed EU delays. It explains the rules and practical assessments.

For whom? Swedish importers of crude oil, natural gas and coal from third countries, procurement and compliance officers at energy or commodity companies, and consultants. A typical end customer who buys energy on the internal market is not automatically covered by the importer rules.

Direct answer: According to Article 27.1, importers must provide information according to Annex IX to the competent authority no later than 31 May each year after the first submission year 2025. The Swedish Environmental Protection Agency is the Swedish competent reporting recipient according to its guidance. A lack of information may require a well-founded justification and an account of actual measures taken to obtain the information, but this is not a general exemption from the reporting obligation.

What Applies Now – and What Could Change in 2027?

Current law: EU Regulation 2024/1787, Article 27 and Annex IX, contains the annual information requirement. Article 28 prescribes according to the current wording a step from 1 January 2027 for measurement, reporting and verification (MRV) of production linked to certain agreements entered into or renewed on 4 August 2024 or later; older agreements have special regulations regarding reasonable efforts. Article 29 has later time steps.

Ongoing EU process – not adopted law: The EU Commission presented on 14 October 2026 a proposal to postpone certain importer requirements. The Council of Ministers adopted its negotiating position 6 November 2026 to among other things propose a one-year postponement of the Article 28 requirements to 2028. That position does not alone change the current regulation. Therefore, check EUR-Lex and the Swedish Environmental Protection Agency again before relying on a new application date. The product does not use 2028 as already decided law.

Exact File List

Excel: nine tabs with functional control flags

Overview, Importers & roles, Agreements, Deliveries, Annex IX, MRV and agreements, Deficiency & actions, Reporting as well as Read me & sources. The overview summarizes registered importers, agreements, deliveries, Annex IX items, open deficiencies and reports. The Annex IX table checks if certain main fields are filled in. If the supply chain or other important administrative data point is missing, ”COMPLETE / document deficiency” is displayed; otherwise, ”Fields filled – manual legal review” is displayed. A status flag does not prove that all information in Annex IX is legally sufficient or that an agreement is MRV-equivalent.

How to use the templates

1. Test if the company is actually an importer according to the regulation's definition and document the decision in template 01.
2. Map relevant third-country producers, agreements, dates, exporters and deliveries.
3. Send supplier request 02 via the agreed contact channel and ask for source-verified information for the points in Annex IX that apply.
4. Log missing information, supplier contacts, reasonable measures and well-founded justification in template 04.
5. Compile annual report draft 03, review Annex IX directly against the current EU text and document the actual reporting year.
6. Evaluate separately if the voluntary contract annex 05 should be negotiated and how current Article 28 and any changes affect the agreement.
7. Let the competent person perform the final legal review, provide relevant information to the Swedish Environmental Protection Agency via the current channel and save actual official receipt.

What is not included?

This is not a public reporting form, a methane measurement service, an emissions calculation tool, technical MRV certification or a guarantee that the authority accepts the information. No file sends data automatically. It does not include a ready signed supplier declaration or the Commission's full clause text; the supplier must provide actual information themselves. Recommendation (EU) 2026/1834 on voluntary contract clauses is guidance, not a new mandatory contract law. This package does not replace individual contract or environmental law advice.

Frequently Asked Questions

What day must the importer report methane information?

According to Article 27.1, the recurring date is 31 May each year after 2025. Check if you are actually reporting liable and what information applies to your agreements, goods and deliveries.

Where does a Swedish importer send the report?

The Swedish Environmental Protection Agency's guidance states that reporting can be done via email and describes a report structure according to the annexes. Check the current procedure directly with the authority when it is time to report.

Is it enough to write “unknown origin”?

No. The Commission's guidance states that unknown origin is not an automatic exemption. Where Article 27.1 allows it, a well-founded justification and documentation of the measures to obtain the information is required.

Does Article 28 apply first from 2028?

A postponement is proposed, but the Council's position from 6 November 2026 is not the same as an adopted EU Regulation. The current wording should be considered until an amendment comes into force.

Is the contract annex binding after download?

No. It is an editable contract draft that must be negotiated, adapted and agreed between the right parties. The recommendation's model clauses are voluntary.

Does Excel perform a legal compliance check?

No. Excel compiles registers and administrative flags. It does not assess the producer's methane emissions, equivalent MRV or the report's full legal content.

Are the documents in English?

Five operational work templates, Swedish guide and Excel are in Swedish. The separate English User Guide provides instructions in English, not legal English-language contract templates.

Sources and control status

Regulation (EU) 2024/1787, especially Articles 27–29 and Annex IX; Swedish Environmental Protection Agency: methane emissions from the energy sector; EU Commission's importer guidance, updated September 2026; Recommendation (EU) 2026/1834 – voluntary clauses; Council negotiating position, 6 November 2026.

Version 1.0 · AI-assisted legal source check 10 November 2026 · No external independent lawyer review or authority certification