Question 3.1.24

LNG commercial transactions, associated with reloads at an EU LNG regasification terminal, (which are physical operations), are only  reportable when the contract explicitly specifies a delivery point to be at or after the entry flange of an EU regasification terminal.  For example, a reload can be associated with the following commercial transactions:

- At the origin EU regasification terminal:

• No title transfer happens, so there is no transaction reporting required (eg counterparty A reload gas from its in-tank inventory).
• A title transfer happens in tank or at or after the entry flange, then this transaction is reportable (counterparty A transfers title to counterparty B at the flange which loads a cargo).

- At the destination regasification terminal:

• In case of a title transfer happens, paragraph A1-3 applies.
• If there is no title transfer or commercial transaction, there is no transaction reporting.

NB: The physical operation of reloading is covered by fundamental data reporting.

Answer:

One terminal

In the Agency’s view it is reasonable to say that, if the reload occurs at the origin EU regasification terminal and no-title transfer happens there is no transaction reporting required. Market participant A reload gas from its in-tank inventory.

However, if a title transfer happens in tank or at after the entry flange, then this transaction is reportable if counterparty A transfers title to counterparty B at the flange which loads a cargo.

Two terminals

Whereas a title transfer happens at an EU destination (Market participant A reload its own cargo from any (EU or non-EU) LGN facility and sell it to Market participant B at another EU LNG facility, destination) this transaction is reportable.

If there is no title transfer or commercial transaction, there is no transaction reporting.