Not all BioLNG is the same: three routes into the tank

Whoever fills an LNG truck in Germany almost always fills up with "bio": 98.5 per cent of LNG sold at German filling stations in 2025 was BioLNG, out of 166,513 tonnes sold in total, according to the industry association Die Gas- und Wasserstoffwirtschaft in February 2026.¹ That figure is an accounting quantity, not a physical one: it says how much biomethane was accounted to the LNG sold, and nothing about the route the gas took to reach the tank.

Yet it is the route that decides what the "bio" label is worth for climate, price and region.

Three routes, one label

In its May 2025 response to the ISCC consultation on mass balancing, the German energy association BDEW outlined three scenarios: "direct", "grid" and "virtual".² We are highlighting this distinction because we believe it is important.

1. Direct liquefaction. Biomethane goes by pipe from the biogas plant to a liquefaction unit, ideally on site, and is trucked from there to the customer as a liquid. The molecule in the tank was produced at that plant. There is an unbroken physical chain from farm to pump. This route is a small part of the market today, but one we will grow: it is the route Eneqor takes from our production units to our customers' tanks.

2. Grid liquefaction. Biogas plants in Germany and across Europe upgrade their raw gas and inject it into the natural-gas grid. Somewhere else a liquefaction plant withdraws gas from the grid and liquefies it. The molecule that ends up in the tank is grid gas, technically a blend of bio and fossil. The biomethane is attributed to the LNG only through a mass-balance ledger. But a real liquefaction step does take place, in Europe, and its emissions are counted.

3. Virtual liquefaction. No grid gas is liquefied at all. An import terminal loads trucks or ships with fossil LNG that arrived by tanker, and that LNG is essentially offset against biomethane injected somewhere in Europe, transferring the sustainability characteristics onto the fossil LNG. BDEW calls this a mere transfer of sustainability attributes onto fossil LNG imported into the EU through a terminal.² Terminals in Belgium, France, Lithuania and Spain, among others, now offer this route.³

The certification schemes allow the terminal route provided plausible conversion factors are applied.² Nationally it is treated differently: Germany and Belgium recognise it, while the Netherlands intended to exclude it when transposing the Renewable Energy Directive RED III.⁴ BDEW itself warns that the lack of transparency may lead to virtual liquefaction being accused of greenwashing.²

What the route means for the climate

Two things count in the carbon balance: what the biomethane was made from, and what emissions are accounted for on the way to the tank.

On feedstock, manure is hard to beat. Digestion captures methane that would otherwise escape from open storage, mitigating the impact of that methane in the atmosphere. The EU credits these avoided emissions: for biomethane from manure with closed digestate storage, the Renewable Energy Directive's default value is roughly minus 80 to minus 100 grams of CO₂ equivalent per megajoule, depending on plant technology.⁵ On paper, a truck running on manure-based BioLNG is carbon-negative — and that applies to manure biomethane on all three routes.

For direct and grid liquefaction, the emissions of the actual liquefaction are also counted. For the terminal route, BDEW finds that unverifiable: liquefaction process emissions of below 0.3 grams of CO₂ equivalent per megajoule are sometimes declared, a value the association cannot reconcile with any liquefaction of methane. In addition, the emissions from producing, liquefying and shipping the imported LNG risk being assigned to no country at all.²

What the route means for the price

For fleet operators this is another important consideration: with grid liquefaction the calculation starts from the grid gas price; with the terminal route, from the price of imported LNG. Both are linked to the global gas market; the biomethane or certificate is a premium on top. Anyone who filled up with LNG in 2022 knows the consequences. And the dependence has grown since: in the first half of 2026, 81 per cent of the European Economic Area's LNG imports came from the United States and Russia, up from 73 per cent a year earlier.⁶

With direct liquefaction, the price is determined solely by the plant's costs (feedstock, upgrading, liquefaction, transport) and by a contract between producer and buyer. Those costs can move too, but they are driven by local factors rather than by intra-European pipelines, international tankers or supply and demand in Asia. That means direct-liquefaction prices can be fixed for years. We will explain more in our next article.

What the route means for credibility

That "bio" on paper is not always "bio" in the tank has a further side. The German market for GHG-quota certificates collapsed in 2023 and 2024 after suspected fraudulent climate projects and biofuels with unverifiable feedstock origin entered the accounting; in April 2026 the legislator responded and made on-site inspections mandatory.⁷ The further apart the biomethane produced and the certificate are, the greater the risk of mislabelling — and the more an unbroken physical chain of custody counts.

Conclusion: ask about the route

Anyone who wants to run a fleet on BioLNG in a way that is climate-friendly and plannable should ask their supplier four questions:

• Where does the biomethane come from?
• From which feedstocks?
• Where was it physically liquefied: at the plant, from the grid, or not at all?
• What does the price depend on?

Only when the answers are traceable and regional does the tank contain what the label says. And only then does the value stay where the biomethane is made: with farms, plant operators and municipalities, rather than in the LNG exporting countries.

Eneqor supplies BioLNG from direct liquefaction at the biogas plant, at a price per kilogram fixed for several years. Talk to us about how we can provide your fleet with fixed-price BioLNG.

Sources

1. Die Gas- und Wasserstoffwirtschaft e.V.: “98,5 Prozent Biomethan – Deutschlands LNG-Lkw tanken nahezu vollständig klimaneutral”, press release, 18 February 2026. gas-h2.de
2. BDEW Bundesverband der Energie- und Wasserwirtschaft: “ISCC consultation on mass balancing”, position paper, 30 May 2025. bdew.de
3. Examples: Fluxys, biomethane liquefaction services at the Zeebrugge LNG terminal; Dunkerque LNG, first bio-LNG loading, 1 July 2025; Ship & Bunker, “Klaipeda LNG Terminal Completes First Virtual Bio-LNG Liquefaction”, 16 October 2025; Argus, “Spain’s Enagas to offer bio-LNG terminal services”, 20 February 2025. fluxys.com
4. Engine: “The Netherlands should allow mass-balancing of green methane – Titan”, 29 September 2025; Safety4Sea: “Organizations urge Dutch government to preserve bio-LNG terminal route”, 30 September 2025. engine.online
5. Directive (EU) 2018/2001 (Renewable Energy Directive), Annex VI Part D, as amended by Directive (EU) 2023/2413: default values for biomethane from manure with closed digestate storage, −79 g (without) and −100 g CO₂eq/MJ (with off-gas combustion), before compression. eur-lex.europa.eu
6. Piria, R.; Szulecki, K.; Lentschig, H.: “Europe’s diversification paradox: Growing US and Russian gas import shares in 2026”, NUPI Policy Brief 15/2026; reported in Berliner Zeitung, 8 September 2026. nupi.no
7. ZfK: “THG-Quote 2026: Diese Änderungen treffen Stadtwerke”, 24 April 2026. zfk.de

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