Question 2.1.42 Data Field (48)
Could the Agency clarify the reporting of EICs and their mapping to the balancing zones/areas, interconnection points, LNG and storage facilities?
In the Transaction Reporting User Manual (TRUM) after consulting the industry through two public consultations, the Agency has indicated that the Energy Identification Code (EIC) to be reported for transaction reporting purposes for Table 1 and Table 2 has to identify the commodity delivery point or zone.
This field reports the EIC Y code (or an alternative code to be agreed with the Agency if the EIC is not available) to identify the delivery and/or balancing point for the contract. In addition, the TRUM clarifies that since gas can also be delivered at the interconnection point, then the EIC Z Code for that interconnector may be used.
Furthermore, in the FAQs on transaction reporting – Question II.3.1.23, the Agency has indicated that where the gas is delivered at an LNG or a gas storage facility, then the EIC W code for that facility should be reported.
Based on more than 1 billion transactions (Table 1 and Table 2) reported to the Agency, it was found that market participants and organised market places are using more than 4000 codes to indicate the delivery points. In some occasions more than 1000 different codes were used to indicate the same balancing zone.
Since the Agency (supported by the input provided by the industry) does not find this diversification reasonable and has seen that 95% of the overall transactions have been reported with the correct EICs, on 26 June 2017 the Agency has published Annex VI to the TRUM (including the list of accepted EICs) in the REMIT Documents section of the ACER website and will only consider the codes listed in the list of accepted codes.
In the Agency’s view, if 95% of the reported transactions are compliant with REMIT, there is no reason for the remaining 5% of transactions to be reported with alternative codes.
Market participants that use different codes for nomination purposes at domestic/industrial aggregate points, distribution zones/networks or production sites should report in any case the EIC of the balancing zone these points are connected to. While they may want to keep using those codes for nomination purposes, they will need to translate those codes into the EIC of the balancing zone they are related to when reporting the transaction to the Agency for REMIT purposes.
With regard to interconnection points, the Agency has explained in Annex VI to the TRUM that the reportable Y EIC code has to belong to the interconnection point where gas is delivered and then transferred to the other side of the interconnection point by the system operator. This case applies to unbundled interconnection capacity only.
In Annex VI to the TRUM the Agency has explained that only the EICs in the list of accepted codes are reportable codes. All the other codes available in the sheet “EICs Validity Check” and flagged as “Invalid” , “ENTSO-E” and “Missing” (please carefully read Annex VI to the TRUM) are not considered compliant with the Agency’s guidance according to Article 5(2) of Commission Implementing Regulation (EU) No 1348/2014.
However, in order to help market participants and organised market places to comply with REMIT, the Agency has given the opportunity to clear their transaction reporting history (related to the EICs) through the online “EIC mapping form” (please see Annex VI to the TRUM for the link).
The online form allows reporting parties to map a previously reported EIC (Missing, Invalid, ENTSO-E list) to a code listed in the "List of Accepted EICs" and to report a code for a zone/area/facility that is not included in the "List of Accepted EICs" (or changing its name/function).
However, market participants that have submitted new codes for domestic/industrial aggregate points, distribution zones/networks or production sites connected to a balancing zone, should not expect the inclusion of those codes in the list of accepted codes, unless the Agency believes there is reasonable ground for their inclusion in the list.
The Agency has already updated the list of EICs codes to accommodate TSOs or market participants requests where the Agency believed there was a reasonable ground for the inclusion of new EICs (this is visible in the EIC list of accepted codes spreadsheet attached to Annex VI to the TRUM).