Question 3.1.21

Contracts for the supply of LNG before the entry flange (FAQs on REMIT transaction reporting, Answer to Question 1.1.9) of an EU LNG regasification terminal  include, for example an exchange of title on the high seas with a free delivery clause/full diversion rights or at a non- EU liquefaction terminal. Based on the principle that the above delivery points are not at an EU LNG regasification terminal, then these contracts should not be reported.

However, if the buyer subsequently decides to send a cargo bought under this type of contract to an EU LNG regasification terminal, the cargo unloading will be subject to fundamental data reporting by the buyer. If the cargo -- once bought under this type of contract -- is “re-traded” by the buyer at or after the entry flange of an EU LNG regasification terminal then the contract relevant to this new transaction will be subject to reporting.

Answer

In the Agency’s view contracts for the supply of LNG before the entry flange of an EU LNG regasification terminal, for example an exchange of title on the high seas outside the EU, are not subject to transaction reporting.

Cargos traded under such contracts are subject to the reporting of fundamental data provided once the cargo is unloaded at an EU LNG regasification terminal.

If the cargo - once bought on the high seas outside the EU under this type of contract is re-traded by the buyer at or after the entry flange of an EU LNG regasification terminal then the transaction related to the new contract will be subject to reporting.