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FAQs on transaction reporting – Question II.3.1.24

LNG commercial transactions, associated with reloads at an EU LNG regasification terminal, (which are physical operations), are only  reportable when the contract explicitly specifies a delivery point to be at or after the entry flange of an EU regasification terminal.  For example, a reload can be associated with the following commercial transactions:

1. At the origin EU regasification terminal:

  • No title transfer happens, so there is no transaction reporting required (eg counterparty A reload gas from its in-tank inventory).
  • A title transfer happens in tank or at or after the entry flange, then this transaction is reportable (counterparty A transfers title to counterparty B at the flange which loads a cargo).

2. At the destination regasification terminal:

  • In case of a title transfer happens, paragraph A1-3 applies.
  • If there is no title transfer or commercial transaction, there is no transaction reporting.

NB: The physical operation of reloading is covered by fundamental data reporting.


Answer:

One terminal

In the Agency’s view it is reasonable to say that, if the reload occurs at the origin EU regasification terminal and no-title transfer happens there is no transaction reporting required. Market participant A reload gas from its in-tank inventory.

However, if a title transfer happens in tank or at after the entry flange, then this transaction is reportable if counterparty A transfers title to counterparty B at the flange which loads a cargo.

Two terminals

Whereas a title transfer happens at an EU destination (Market participant A reload its own cargo from any (EU or non-EU) LGN facility and sell it to Market participant B at another EU LNG facility, destination) this transaction is reportable.

If there is no title transfer or commercial transaction, there is no transaction reporting.

Last update: 14/12/2016   RSS_Icon Subscribe to this Page’s RSS