OXFORD INSTITUTE OF ENERGY STUDIES | Entering the 2020s, LNG sellers are operating in an increasingly oversupplied global market, thus facing the problems of whether and where they will be able to ‘find a home’ for their cargoes. Given that the EU is the only liquid gas market with regulated third party access (TPA) to LNG import terminals, the sellers will always be able to place a cargo in the EU for which no other market can be accessed unless the owner/buyer agrees, and hence will need to know and understand the TPA rules for EU LNG import terminals. As no dedicated LNG-specific EU regulation exists and the Third Gas Directive and Gas Regulation 715 left a significant degree of discretion to the regulated terminal operators in respect of capacity allocation mechanisms, UIOLI procedures, and tariffs, enabling the operators to choose different ways of compliance, or apply for an exemption. This has resulted in a situation where the LNG import terminals in the EU are governed by a patchwork of terminal codes developed by their operators, the NRA guidance, and the exemptions, thus making it extremely difficult for an LNG seller to understand the rules.
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