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.