Gas Distributors for Sustainability

European Commission Public Consultation: Circular Economy Act GD4S Response to the Call for evidence November 2025 Gas Distributors for Sustainability (GD4S) brings together leading gas distribution operators from nine EU Member States — France, Greece, Ireland, Italy, the Netherlands, Poland, Portugal, Romania, and Spain — plus the UK.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached GD4S feedback on the proposed Industrial Accelerator Act (IAA). In our response, we welcome the Commissions proposal as an important step to strengthen Europes industrial competitiveness and accelerate decarbonisation.

Gas Distributors for Sustainability (GD4S) represents 12 major gas distribution companies across ten European countries, including the UK. Collectively, we serve over 54 million customers through a network exceeding 867,000 km. As Distribution System Operators (DSOs), our core mission is to ensure the safe, secure, and reliable delivery of both natural and renewable gases to homes, businesses, and communities.

GD4S welcomes the ongoing revision of the Renewable Energy Directive (REDII). The publication of the Energy System Integration and Hydrogen strategies has underlined the importance of renewable gases in achieving carbon neutrality in a cost-efficient way. The revision of REDII is the legislative opportunity to stimulate their development.

GD4S welcomes the expected revision of the Renewable Energy Directive (REDII) as part of the Energy System Integration Strategy and the possibility to comment on the Inception Impact Assessment (IIA). With the publication of the ESI and Hydrogen strategies the Commission has underlined the important role renewable gases will play to reach carbon neutrality in a cost-efficient way.

Gas Distributors For Sustainabilty (GD4S) welcomes the EC initiative on critical raw material. Availability and affordability of natural resources will drive sustainable economic models and energy transition. Decision-makers need information and data to manage uncertainty and adverse conditions.

The building sector is one of the hardest to abate. Firstly, the large variety of technical, social, societal issues, and high financial impacts, make it a very sensitive topic for our citizens, and requires a building-to-building approach, with no silver bullet.

GD4S welcome the EC decision to revise the EPBD. Massive and fast deployment of CO2 efficient solutions are indeed required in the building sector, the largest energy consumer and CO2 emitter in Europe, to meet the 2030’s CO2 objectives. These solutions must adapt to the high variety of local conditions across Europe.

Gas Distributors for Sustainability (GD4S) welcomes the Commission’s Intitative on a Climate Law that will contribute to the implementation of the Paris agreement on climate change and ensure an ambitious and just EU climate policy. GD4S supports the initiative’s goal to enshrine the EU objective of climate neutrality by 2050 in legislation.

Gas Distributors for Sustainability (GD4S) brings together leading gas distribution operators from nine EU Member States and the UK. Collectively, they manage 937,000 km of networks and supply sustainable energy to more than 60 million customers.

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. We welcome the opportunity to provide feedback on the “EU Green Deal – Carbon Border Adjustment Mechanism.” GD4S acknowledges that this mechanism will move towards protecting the competitiveness of the European economy.

GD4S welcomes the EC decision to revise the EED, and its inclusion of the Energy Efficiency First Principle. A broader view of efficiency, such as Life Cycle Analysis (LCA) and system benefits, is required to ensure that carbon emission are not just displaced but avoided. - An LCA to assess the overall CO2 and cost-efficiency, including in manufacturing and recycling.

The revision of the Energy Efficiency Directive is an important step to cement the road to climate neutrality including recent related works such as the Energy System Integration, the renovation wave and the Hydrogen strategy. At GD4S, we are convinced that gas solutions and renewable gases, can bring key contributions to achieve a fast, safe and sustainable energy transition and meet the increased 2030 targets.

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. GD4S welcomes this opportunity to provide feedback on the roadmap to revising the Energy Taxation Directive. Overall, we support the Directive being updated to actively support delivery of the European Green Deal.

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to contribute to the European Commissions Call for Evidence on the Renewable Energy Framework post-2030. Due to space limitations in the response form, our full and detailed input is provided in the attached document .

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to provide feedback on the proposed amendment to the European Climate Law. Gas Distributors for Sustainability (GD4S) represents major gas distribution system operators (DSOs) from nine EU Member States France, Greece, Ireland, Italy, the Netherlands, Poland, Portugal, Romania and Spain and the UK, supplying more than 60 million customers and…

Gas Distributors for Sustainability (GS4S) welcomes the European Commission's proposal to facilitate the decarbonisation of the transport sector. We firmly believe in the principle of technology neutrality; therefore, we are not in agreement with the Commission's approach which effectively limits new vehicles to technology which meets the requirement of Zero Emission Vehicles (ZEV).

Gas Distributors for Sustainability (GD4S) welcomes the efforts of the European Commission to reduce GHG emissions by at least 55% by 2030 (from 1990 levels) and to reach a 90% reduction in mobility by 2050. Today the transport sector accounts for 25% of Europe GHG and this share kept increasing notably because convention fuels still represent over 96% of new light vehicles.

Gas Distributors for Sustainability (GD4S) welcomes the timely publication of the ECs draft legislative proposal on Gas networks - revision of EU rules on market access (Regulation), in light of the recent EC REPowerEU Communication. This proposal will act as a key enabler to GD4S’ vision and we welcome the clarity provided.

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to provide feedback on the “Gas networks - revision of EU rules on market access” IIA consultation. In particular, we agree with the EC’s assessment that “full electrification is unlikely to be technically or economically viable”, and that “the share of gaseous fuels to total EU energy consumption in 2050 would be about 20%”, broadly in line with…

Gas Distributors for Sustainability (GD4S) represents major gas distribution system operators (DSOs) from nine EU Member States France, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Romania and Spain and the UK, jointly operating over 937,000 km of gas networks and supplying more than 60 million customers.

Gas Distributors for Sustainability (GD4S) welcomes the European Commission's proposal to invest in infrastructure to facilitate the decarbonisation of transport and deliver on energy transition objectives. GD4S believes that a technology-neutral approach is essential in the context of designing infrastructure models, adapted to a decarbonised energy system.

Gas Distributors for Sustainability (GD4S) represents leading gas distribution operators from nine EU Member States France, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Romania, Spain and the UK. GD4S supports the EUs net-zero target by enabling the collection and distribution of renewable gases.

GD4S welcomes the Commissions initiative to establish clear and simple guidance for the Do No Significant Harm (DNSH) principle. As gas DSOs fully committed to integrating renewable gases into existing networks, we believe harmonised rules are essential to ensure EU funds effectively support the green transition without creating unnecessary administrative burdens.

Gas Distributors for Sustainability calls for a system-wide, technology-neutral approach that embraces renewable gases, sector coupling, supports consumer empowerment, and duly consider cost-efficiency, system resilience and social fairness. Gas grids are critical infrastructure that serves millions of households and businesses.

GD4S welcomes the European Commission (EC) proposal for a new TEN-E Regulation (COM(2020)824). The proposal paves the way for the future role of gas infrastructures in the energy transition, enabling the development of renewable gases and contributing to energy system integration.

GD4S is an association bringing together seven gas DSOs in Europe, each of them a leader in their respective country (France, Greece, Italy, Ireland, Portugal, Romania and Spain). GD4S is committed to contributing to the decarbonisation of the gas sector with renewable gases (biomethane, synthetic methane and renewable hydrogen).

GD4S welcomes the publication of the Proposal on Methane Emissions reduction in the energy sector. Reducing emissions is a critical step for the sustainability of the gas industry and ensuring safe operations and limiting GHG emissions is at the core of our action as gas Distribution System Operators (DSO). The proposal goes in the right direction when modelling its action on the existing OGMP initiative.

GD4S welcomes the EC initiative for the reduction of Methane Emissions through the adoption of specific legislation, as well as the opportunity to provide feedback on this consultation As stated in previous documents to the attention of the EC, GD4S strongly endorses the EU climate neutrality goal by 2050 and supports the adoption of measures based on a holistic approach to all available technologies and on the role…

Gas Distributors for Sustainability (GD4S), representing major gas distribution operators from ten European countries, supports the EUs net-zero objective by advancing renewable gas collection and distribution across 929,500 km of networks serving over 60 million customers.

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to contribute to the European Commissions Call for Evidence on the Energy Efficiency Framework post-2030. Due to space limitations in the response form, our full and detailed submission is provided in the attached document .

GD4S supports the European Commissions proposal to simplify, strengthen and modernise the Regulation on the Governance of the Energy Union and Climate Action. This revision is a critical opportunity to prepare an enabling policy framework for the decade ahead and to achieve objectives of Paris Agreement.

Gas Distributors for Sustainability (GD4S) represents leading gas distribution operators from nine EU Member States France, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Romania, Spain and the UK. GD4S supports the EUs net-zero target by enabling the collection and distribution of renewable gases.

We, Gas Distributors for Sustainability, firmly commit to the decarbonization of transport sector notably in an energy mix where each alternative fuel has a role to play including biomethane (bioNGV). To achieve the greenhouse gas emission reduction targets, set by the Green Deal, the European Commission must promote all technologies that can effectively decarbonise road transport.

Gas Distributors for Sustainability (GD4S) welcomes the timely publication of the ECs draft legislative proposal on Gas networks - revision of EU rules on market access (Directive), in light of the recent EC REPowerEU Communication.

Gas Distributors for Sustainability (GD4S) supports the European Union's ambition to boost energy efficiency and decarbonise the heating sector. However, the current draft regulation revision risks diverging from its primary objective: helping consumers to identify the most efficient appliance for their specific needs (suitable for their specific building, budget and local energy infrastructure).

Energy Labelling was designed at a time when electricity was mostly fossil based, to help consumers select the most efficient solution to meet their needs, with the lowest energy consumption costs for them. This approach was relevant for comparing similar products, using the same energy, such as two fridges, but far less relevant when comparing appliances offering different services, using different energy vector…

Energy Labelling was designed at a time when electricity was mostly fossil based, to help consumers select the most efficient solution to meet their needs, with the lowest energy consumption costs for them. This approach was relevant for comparing similar products, using the same energy, such as two fridges, but far less relevant when comparing appliances offering different services, using different energy vector…

GD4S is a European association gathering gas and electric DSOs engaged in a cost effective and resilient transition, optimizing all renewable energies and energy infrastructures, in order to leave no-one behind. Energy security is a crucial aspect of the energy trilemma and a key accomplishment of the energy system, which must be considered in conjunction with sustainability and affordability.

Gas Distributors for Sustainability (GD4S) strongly supports the EUs objective of reducing greenhouse gas emissions from buildings and industry and recognises the important role of ecodesign requirements in improving energy efficiency.