All documents exchanged between DG Energy and/or DG Climate Action and representatives of Shell plc, Shell Energy Europe, Nature Energy, or Shell Biogas
Dear Energy,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:
All documents exchanged between DG Energy
and/or DG Climate Action and representatives of Shell plc,
Shell Energy Europe, Nature Energy, or Shell Biogas, concerning:
(a) Biomethane guarantees of origin and cross-border certificate
trading under RED II/III;
(b) The Hydrogen and Gas Decarbonisation Package;
(c) Shell's consultation responses on these topics not already
published on the "Have Your Say" portal;
for the period 1 January 2020 to present.
Precedent: GestDem 2017/1771 (DG Energy communications with
Shell, 10 attachments released).
Yours faithfully,
Martin Collignon
Dear Sir or Madam,
We are writing to you concerning your request for access to documents sent
on 05/06/2026 and registered on 06/06/2026 under case number 2026/2890.
Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.
You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.
Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.
Why do we need your personal postal address?
Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:
• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.
The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.
Yours faithfully,
Secretariat-General - Access to Documents
European Commission
References
Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...
Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 05/06/2026 and registered on 06/06/2026 under the case number
2026/2890.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 29/06/2026. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Secretariat-General - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Dear Mr Collignon,
We are writing concerning your request for access to Commission documents
registered on 06.06.2026 under case number 2026/2890.
Your application concerns a very large number of documents over a long
period of time ( 2020-2026), which need to be assessed individually. Such
a detailed analysis cannot be carried out within the normal time limits
set out in Article 7 of Regulation (EC) No 1049/2001.
Moreover, the handling of your request involves the assessment of very
voluminous documents originating from third parties. The analysis of these
documents, together with the need to consult the third parties concerned
in accordance with Article 4(4) of Regulation (EC) No 1049/2001, cannot be
expected to be completed within the normal time limits set out in Article
7 of Regulation (EC) No 1049/2001.
However, Article 6(3) of Regulation (EC) No 1049/2001 also provides for a
possibility to confer with an applicant informally with a view to finding
a fair solution when an application relates to a very long document or
concerns a very large number of documents.
In accordance with the case law of the EU Courts, such a solution can only
concern the content, or the number of documents requested, not the
deadline for replying ([1]^[1]). This means that the scope of the request
must be reduced in a way that would enable its processing within the
extended deadline of 15 + 15 working days.
Based on the above-mentioned provision, in order to narrow down the scope
of your application and to reduce it to a more manageable amount of
documents, we would kindly ask you to specify and precise the objective or
the consultations you are interested in.
In order to enable us to respect the time-limits of Regulation (EC) No
1049/2001, please reply to this proposal for a fair solution within five
working days at the latest.
In the absence of a reply within five working days, we will restrict the
scope of your application to those parts that can be dealt with within the
extended deadline of 30 working days.
Yours sincerely,
DG ENER Access to Documents Team
────────────────────────
[2]([1]) Judgment of the Court of Justice of 2 October 2014,
Strack v European Commission,
C-127/13,(hereinafter referred to as the ‘Strack v Commission judgment’),
EU:C:2014:2250, paragraphs 26-28
References
Visible links
1. file:///tmp/foiextract20260612-3824415-6ugd5x#_ftn1
2. file:///tmp/foiextract20260612-3824415-6ugd5x#_ftnref1
Dear [email address],
Thank you for your letter of 12 June 2026 under case 2026/2890.
I would like to reduce my request to the following three categories, which I believe are specific enough to be processed within the extended deadline:
(1) Meetings and correspondence concerning the treatment of biomethane Guarantees of Origin in Implementing Regulation (EU) 2022/996, specifically:
The inclusion of LNG terminals in the definition of “interconnected infrastructure” (Article 2(18));
The treatment of the EU interconnected gas grid as “one single mass balancing system” for gaseous fuels (Recital 5 and Article 19);
Any input from Shell, Shell Energy Europe, Nature Energy, or Shell Biogas on the drafting or implementation of these provisions.
Period: 1 January 2021 to 31 December 2025 (covering the adoption of IR 2022/996 and the Shell/Nature Energy acquisition).
(2) Shell’s consultation responses or position papers submitted directly to DG Energy and/or DG Climate Action (i.e., not via the public “Have Your Say” portal) concerning:
The Hydrogen and Gas Decarbonisation Package (Directive 2024/1788 and Regulation 2024/1789);
The treatment of biomethane certificates in cross-border trade.
Period: 1 January 2022 to 31 December 2025 .
(3) Records of meetings between DG Energy officials and Shell representatives (as recorded in DG Energy’s meeting lists or agendas under the Commission’s transparency commitments) where biomethane, guarantees of origin, or the gas decarbonisation package were discussed.
Period: 1 January 2022 to 31 December 2025.
I believe this narrowing — from the original open-ended request covering all documents on all topics since 2020 — to three specific regulatory instruments and defined time windows represents a substantial reduction in scope. I am of course open to further discussion if this remains too broad.
Yours faithfully,
Martin Collignon
Dear Mr Collignon,
We are writing concerning your request for access to Commission documents
registered on 06/06/2026 under case number EASE 2026/2890.
We are currently working on your request. However, we have not yet been
able to gather all the elements necessary to carry out a full analysis of
your request. We will not be able to send you the reply within the
prescribed time limit expiring on 29/06/2026. The application concerns
documents held by different Services, which must be consulted.
Therefore, in line with Article 7(3) of [1]Regulation (EC) No 1049/2001,
we need to extend this time limit by 15 additional working days. The new
time limit expires on 20/07/2026.
We apologise for any inconvenience this may cause.
Kind regards,
DG ENER Access to Documents Team
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
