On March 18, 2025, the Belgian government approved a royal decree that introduced two restrictive measures targeting liquified natural gas (LNG) from Russia. The decree established:
- a ban on providing reloading services within the European Union (EU) for transshipment operations involving LNG originating in or exported from Russia; and
- a ban on offering, directly or indirectly, technical assistance, brokerage services, financing, or financial aid related to the above restriction.
The royal decree was published in the Moniteur Belge, the Belgian official journal, on March 25, 2025, and took effect immediately.
LNG reloading is part of a transshipment process where liquefied natural gas is transferred from one carrier to another. To enforce the bans, authorities must accurately determine the origin of LNG arriving in Belgium. Article 1 of the royal decree requires terminal users to declare whether their LNG is of Russian origin at least four days before unloading. The directorate-general for navigation then verifies the declaration by reviewing, among other factors, the shipping route of the LNG carrier.
The Belgian sanctions have had a big impact on the Zeebrugge LNG terminal, operated by Fluxys LNG. The terminal is the only facility in Belgium capable of reloading LNG, and it has served as a hub for the transport of Russian gas. Under the bans, beginning on March 27, 2025, users of the terminal can no longer refuel with Russian LNG.
Article 7 of the royal decree lists two exceptions to the bans:
- when an EU member state declares that the LNG is essential for its energy supply; and
- when the LNG is used to supply fuel for use by ships, a process known as bunkering.
Background
Since March 27, 2025, refueling with Russian LNG or LNG exported from Russia has been prohibited across the EU. The Belgian royal decree is part of the EU’s 14th package of sanctions against Russia aimed at curbing revenues from Russian natural gas, as outlined in Regulation (EU) No. 2024/1745, which amends Regulation (EU) No. 833/2014. The bans apply to new contracts dating from June 25, 2024, and, starting on March 27, 2025, to contracts signed before that date.
Louis Gilbert, Law Library of Congress
April 8, 2025
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