Sanctions on the reloading of Russian LNG in Belgium

As of 27 March 2025, it is prohibited in the European Union to reload liquefied natural gas (LNG) of Russian origin or LNG exported from Russia. This ban is part of the 14th package of sanctions against Russia, set out in EU Regulation 2024/1745, and aims to limit Russian natural gas revenues. It has applied to new contracts since 25 June 2024 and as of 27 March 2025 it will also apply to contracts concluded before 25 June 2024.

Enforcement of the ban

The European Regulation is directly applicable, but the federal government has laid down additional rules and guidelines in the Royal Decree of 18 March 2025 concerning restrictive measures regarding the transshipment of Russian LNG in view of Russia’s actions destabilising the situation in Ukraine to correctly apply the ban and regulate exceptions. That decision remains valid as long as the European Regulation is in force.

For questions about the application of the ban on reloading services, you will find all the necessary information on this page. In case of contradictions with official legislation, including the royal decree, the legal framework always prevails.

What does the ban mean for the Zeebrugge LNG terminal?

The Zeebrugge LNG terminal, operated by Fluxys LNG, is the only location in Belgium where LNG can be reloaded. From 27 March 2025, users of the terminal will no longer be allowed to reload Russian LNG.

There are two exceptions to the ban:

1. If an EU member state declares that the LNG is necessary for its energy supply.
2. If the LNG is used as marine fuel (bunkering).

What is a transshipment of LNG?

Reloading (Russian) LNG is part of a transshipment. This is the process of transferring liquefied natural gas (LNG) from one methane tanker to another.

This can happen in two ways:

1. Direct transfer: LNG is transferred directly from one methane tanker to another, if both ships are in the harbour at the same time.
2. Storage and later reloading: LNG is first unloaded and temporarily stored in a tank at the LNG terminal. At a later date, it will be reloaded onto another ship.

In Belgium, transshipment takes place exclusively at Fluxys LNG's LNG-terminal in Zeebrugge.

Why is Russian LNG transhipped?

Transshipments of Russian LNG are developed to use as efficiently as possible Russia's fleet of methane tankers that can operate as icebreakers.

The majority of Russian LNG is produced in Yamal, an area with extreme weather conditions.

• In winter, the sea route from Yamal to Asia is not navigable, even with icebreakers.
• The route from Yamal to Europe does remain accessible.
• Therefore, Russian LNG is first brought to European ports such as Zeebrugge, Montoir in France or Murcia in Spain. There it is transhipped onto regular methane tankers that make the rest of the journey to Asia.

How is Russian LNG identified?

To enforce the ban on the reloading of Russian LNG, it is essential to correctly identify the origin of LNG arriving in Belgium. LNG terminal users must declare whether their LNG is of Russian origin at least four days before unloading. That declaration is verified by the DG Navigation by checking, among other things, what the shipping route of the LNG tanker was.

The declaration must be made using the standard form, found on the Fluxys website, and must be sent to the following authorities:

• For Fluxys: dispatching@fluxys.com
• For the Maritime Security Cell: maritime.security@mobilit.fgov.be
• For the DG Energy: declarationlng@economie.fgov.be

What about Russian LNG stored in Belgium?

When LNG is unloaded in Zeebrugge, there are several options for processing it:

• Regasification and transport (most common):  LNG is converted back into gas and injected into the natural gas transport network for use in Belgium or transit to neighbouring countries.
• Temporary storage: LNG can be temporarily stored in one of the five tanks in Zeebrugge.
• Truck loading: LNG can be loaded onto trucks for further transport.
• Bunkering: LNG is used as a fuel for ships.
• Transshipment: LNG is reloaded onto a ship and transported abroad.

Once the LNG is unloaded, the LNG terminal operator, Fluxys LNG, records the origin of the gas (Russian or non-Russian). Fluxys also keeps track of how the LNG is processed (regasification, bunkering, truck loading, etc.).

Reloading of Russian LNG

Reloading of Russian LNG in Belgium

Those wishing to reload LNG must declare their intentions at the latest 7 days before the ship arrives in Zeebrugge:

• Is it Russian LNG or non-Russian LNG?
• Is the reloading intended for bunkering or for transport abroad?
• If the LNG is intended for transport abroad, the user must also specify the destination.

To disclose intentions regarding the reloading of LNG, use the declaration of intent that can be found on the Fluxys website [LINK] and then send it to Fluxys LNG, the Maritime Security Cell and the DG Energy (see above).

Russian LNG may not be reloaded for transport to a non-EU country. This is strictly forbidden. Transport to an EU member state is only allowed if that member state declares that the LNG is necessary for its energy supply. In that case, the Directorate-General for Energy (DG Energy) can issue an authorisation.

What if Russian LNG is reloaded in another EU member state and comes to Belgium?

To enable users of the Zeebrugge terminal to import LNG loaded elsewhere, the federal government also developed an arrangement in the royal decree. That arrangement allows carriers to bring Russian LNG, which was reloaded in another EU member state, to Zeebrugge, subject to permission.

Barring exceptions, this LNG in Belgium is:

• used for consumption, or
• transported by pipeline to a neighbouring country or to another EU member state.

How do you apply for permission?

An LNG terminal user can apply to the DG Energy to offload Russian LNG in Belgium that has been reloaded in another EU member state.

The DG Energy assesses whether the LNG is necessary for the energy supply in Belgium. If approved, the DG Energy issues a certificate that can be used in the EU Member State where the reloading operation takes place.

If the LNG is destined for a third EU Member State, the DG Energy can also provide such a certificate on the condition that the carrier declares that the LNG cargo is necessary for the energy supply of that third country.

How to apply for a certificate?

• Submit your application via declarationlng@economie.fgov.be
• Use the standard form below.
• The GD Energy undertakes to reply within two calendar days if the cargo is destined for the Belgian energy supply.