2025IADC, Regulation, and LegislationNovember/December

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European Council votes for proposal banning Russian oil and gas imports in 2026

On 20 October, the European Council approved a draft European Commission proposal that bans the imports of Russian crude oil and natural gas starting 1 January 2026.

Under the proposed rules, energy operators will be able to invoke force majeure to terminate Russian gas import contracts, since the legally binding prohibition on further imports, as provided by the new regulation, is explicitly defined as a sovereign act beyond their control.

The proposal provides limited exceptions for existing contracts. Short-term contracts, which have not been defined in the draft, would be allowed to continue until 17 June 2026, while long-term contracts may run until 1 January 2028. Amendments to existing contracts will be permitted for narrowly defined operational purposes and cannot lead to increased volumes, except for some specific flexibilities for landlocked EU member states affected by recent changes in supply routes.

The approved draft also streamlines customs obligations by establishing lighter documentation requirements and procedures for imports of non-Russian gas. In such cases, only proof of the country of production must be provided to the authorizing authorities before gas enters the EU’s customs territory, while more information will be requested for gas imports from Russia during the transition (including the date and duration of the contract and the quantities contracted).

The draft proposal also requires both categories of gas imports (pipeline and LNG) to be subject to a prior authorization regime in order to ensure that the prohibition will work in practice.

The proposal still needs to be sent to the European Parliament for a vote, which has not been scheduled as of the time of this publication.

Coalition discusses permitting reform with US Congress

IADC VP of Policy Joe Lillis (right) recently joined a coalition representing more than 80% of US oil and gas production to meet with various members of the US Congress. The discussion on permitting reform focused, in part, on overhauling the National Environmental Policy Act, which requires federal agencies to assess the environmental effects of proposed major federal actions prior to decisions. Participating organizations included the Western Energy Alliance, the Texas Alliance of Energy Producers, the Independent Petroleum Association of America (IPAA) and IADC. Pictured, from left, are Daniel Naatz, IPAA CEO; Chris Kearney, Principal at the Ferguson Group; Tim Tarpley, President of the Energy Workforce & Technology Council; US Rep. August Pfluger (R-Texas); and Mr Lillis.

Federal court rules against leasing ban in US Gulf, opens path for lease sales

On 2 October, a federal judge in Louisiana overruled a decision from former US President Joe Biden that closed 625 million acres of federal waters to future oil and gas leasing. Judge James Cain of the US District Court for the Western District of Louisiana said in his ruling that Mr Biden’s executive order, issued in January 2025, violated the Outer Continental Lands Act because it did not include a provision allowing a future president to overturn it.

The ruling allows the Trump Administration to proceed with announced plans to schedule lease sales in the once-banned areas. If the ban had stood, only the federal waters of the western and central US Gulf would have remained open for future oil and gas leasing.

The states of Louisiana, Alabama, Alaska, Georgia and Mississippi, along with the American Petroleum Institute (API) and the Gulf Energy Alliance, filed a federal suit on 17 January to block Mr Biden’s order.

In a statement, API Senior Vice President and General Counsel Ryan Meyers said, “We welcome the court’s decision to vacate this politically motivated decision and ensure our nation’s vast offshore resources remain a critical source of affordable energy, government revenue and stability around the world. This ruling marks another important step in advancing a robust new five-year offshore leasing program.”

US EPA considers terminating GHG Reporting Program

On 12 September, the US Environmental Protection Agency (EPA) released a proposal to end the Greenhouse Gas Reporting Program (GHGRP), which currently requires certain industrial facilities to measure and report greenhouse gas (GHG) emissions to the EPA. The EPA said in a statement that the move is aimed at reducing regulatory burden.

Currently more than 8,000 facilities, suppliers and CO2 injection sites submit annual data under the GHGRP, covering 47 different industries, including petroleum and natural gas systems.

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