Spain reveals the procedure for obtaining renewable gas origin guarantees

On September 22, 2021, the Ministry for the Ecological Transition and the Spanish Demographic Challenge (MITECO) has issued a draft royal order establishing a system for providing GoOs (guarantees of origin) for renewable gases like green hydrogen and biogas across the country. Spanish public and energy sector members were able to express their opinions on the proposed procedures during public participation in the decree that lasted until October 14, 2021.

The decree partially implements Directive 2018/2001 of the European Council and the Parliament on the advancement of the use of renewable energy sources, with a focus on the sustainability standards and the reduction of carbon from bioenergy and renewable gas.

What is the goal of Spain’s GoO procedure?

Directive 2018/2001 mandates the EU Member States to guarantee that gas derived from renewable sources meets the objective, transparent, as well as non-discriminatory requirements. The PNIEC (Spanish Integrated Energy and Climate Plan) 2021-2030 (Measure no.1.8) and the Hydrogen Roadmap, accepted by the government of Spain in October of 2020, both need these conditions. It is also hoped that by recognizing and earning GoOs for the renewable gases, Climate Change Act 7/2021 of May 21, 2021, Spain, will contribute to the goal of promoting the manufacturing and utilization of such energy.

What is the scope of it?

Although gases like hydrogen and biomethane are commonly thought to be low-carbon, they are only genuinely “green” if they are made from renewable resources and/or emit little or no carbon. Secretary of State for Energy of Spain is overseeing the growth of a GoO system for renewable gases, which is the country’s first regulatory step toward decarbonizing this sector of the energy market.

In the case of biomethane, a significant step has already been taken in terms of regulating how GoOs are certified, with the development of UNE 0062:2020 by the SEDIGAS (Spanish Gas Association) and the UNE (Spanish Association for Standardisation) in June 2020.

The standards for ensuring the biomethane’s origin before it gets injected into this gas network are laid forth in this new UNE specification. To do so, it establishes terminology and definitions for the registration, issuance, transfer, as well as cancellation of certificates in accordance with directives on energy efficiency, renewable energy, and the domestic natural gas market.

What rules will govern the system?

In Spain, MITECO has been selected as the Responsible Entity for the management and development of the GoO renewable gas system. However, until it is provided with the required resources, ENAGAS, the Spanish energy business and European TSO (transmission system operator), that owns and runs Spain’s gas grid, assumes its responsibilities.




Following a report from CNMC, Spain’s competition regulator, (ENAGAS needs to draft a management process proposal to be authorized by the Secretary of State for Energy within three months of the new system’s implementation.

Among the topics covered in this management procedure are:

  • Regulation of the renewable gas production facility registration process;
  • The certificate, the responsibilities and privileges of the GoO holders, and the necessity of guarantees (where necessary) are all defined.
  • Regulation of the communication mechanism with negotiation bodies, as well as entities responsible for managing GoO of electricity and third nations (this potential is relevant given the fact that biogas (Germany) and biomethane (Denmark, France, Austria, Italy) are already generated in the EU);
  • Energy measurement process regulation; and
  • Regulation of claims.

The Responsible Entity will organize a Committee of Renewable Gas Producers, comprised of representatives from the Responsible Entity and the CNMC, that will be aware of and informed about the GoO System’s operation and management, as well as draft and channel ideas to improve its performance. This Committee may include LNG transport and distribution industry players, market consumers, their associations, and CORES.

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