The European Union’s response to Russia’s invasion of Ukraine has been framed as a necessary acceleration of decarbonisation and diversification away from Russian gas. REPowerEU promises to reduce fossil dependence while securing supply. However, a growing body of critical work argues that the architecture of EU gas governance structurally embeds regulatory capture and conflicts of interest, particularly in the way EU institutions rely on ENTSOG, Gas Infrastructure Europe (GIE) and major operators such as Fluxys for modelling, planning and implementing the liquefied natural gas (LNG) build-out. This essay outlines these system-level critiques, using the US–EU LNG expansion and the case of Zeebrugge as key examples.

A first strand of critique concerns the institutional role of ENTSOG. Under EU law, ENTSOG, a network composed of transmission system operators (TSOs), is tasked with producing the Ten-Year Network Development Plan (TYNDP), which forecasts gas demand and proposes infrastructure projects that then feed into the Commission’s list of Projects of Common Interest (PCIs) eligible for EU funding (Global Witness, 2020). Global Witness shows that ENTSOG’s TYNDP has repeatedly overestimated future gas demand, with forecasts between 2013 and 2019 systematically above realised consumption and above levels compatible with EU climate targets (Global Witness, 2020, pp. 5–7). Because only projects included in the TYNDP can become PCIs, ENTSOG effectively co-defines the menu of gas projects that the Commission can support, while its member companies are also the main beneficiaries of those investments. This is not a marginal issue; between 2013 and 2020, about €4.5 billion in EU funds went to 44 new gas projects, with 90 percent of that funding flowing to ENTSOG member companies (Greenpeace International, 2023b). The result is a structurally conflicted arrangement where the entities that profit from new pipelines and LNG terminals also help determine whether those assets are “needed”.

A second line of critique focuses on how this knowledge monopoly shaped REPowerEU. Corporate Europe Observatory argues that the Commission’s 2022 REPowerEU package reproduced core assumptions promoted by the gas industry, particularly high gas demand scenarios and a strong emphasis on infrastructure solutions, including new LNG terminals, interconnectors and hydrogen-ready pipelines (Corporate Europe Observatory, 2022). Independent modelling cited by NGOs and think tanks suggests that existing pipelines and LNG terminals would have been sufficient to meet demand through at least 2030, even under scenarios with Russian supply disruptions, if combined with ambitious efficiency and renewables deployment (Global Witness, 2020, pp. 6–7). Nevertheless, REPowerEU channelled new public subsidies and fast-track procedures toward additional gas infrastructure, including floating storage and regasification units and terminal expansions. For critics, this illustrates regulatory capture not as bribery but as epistemic dependence, as the Commission relies on data, scenarios and project pipelines produced by entities with a structural interest in keeping gas central to Europe’s energy system.

GIE, the lobby group for gas storage, LNG and transmission operators, plays a complementary role. Its 2022 paper on making REPowerEU “successful with gas infrastructure” explicitly framed new LNG terminals and related assets as indispensable security instruments, just as corporate owners stood to benefit from a wave of “emergency” investments. Corporate Europe Observatory and allied groups argue that this helped tilt political debate toward supply-side responses, while the potential of demand reduction and accelerated electrification was comparatively underplayed (Corporate Europe Observatory, 2022). In this reading, REPowerEU is not simply a neutral response to a crisis but an outcome of a long-standing lobbying infrastructure that positioned gas operators as “technical experts” whose preferred solutions coincidentally secured their own asset base well into the 2030s.

Fluxys and the Zeebrugge LNG terminal offer a concrete illustration of these structural issues in the US–EU LNG context. Fluxys is both an ENTSOG member and a key operator of LNG and pipeline infrastructure in Belgium and beyond (Global Witness, 2020, p. 2). Greenpeace Belgium’s report The LNG Trap documents how Zeebrugge has become the single largest hub for Russian LNG in the EU, handling roughly a quarter of all Russian LNG volumes since 2021, while at the same time importing rising quantities of US LNG (Greenpeace Belgium, 2025, pp. 2–5). Despite the EU’s goal of phasing out Russian fossil fuels, Russian LNG imports through Zeebrugge actually increased in 2022 and 2023, and remained high in 2024–2025, even after a ban on transshipment, because cargoes are regasified and enter the European grid as “European” gas (Greenpeace Belgium, 2025, pp. 3–5).

At the same time, the report shows that European companies have signed a wave of long-term offtake contracts for US LNG, and that a 2025 EU–US trade deal includes a pledge to purchase around 750 billion USD of US energy over three years, including LNG (Greenpeace Belgium, 2025, pp. 3, 6). The combination of persistent Russian LNG flows and locked-in US LNG contracts leads Greenpeace to characterise Europe’s position as one of “dual dependence”: swapping Russian pipeline gas for Russian and US LNG without structurally reducing gas demand (Greenpeace International, 2023a; Greenpeace Belgium, 2025). In this setting, Fluxys benefits from high utilisation and expanded capacity at Zeebrugge and Dunkirk, even as EU climate law implies a rapid decline in gas consumption over the coming decade.

These dynamics are reinforced by a broader pattern of LNG overbuild. Greenpeace’s Who Profits from War notes that in 2022, European LNG regasification capacity was only about 63 per cent utilised, yet numerous new terminals and expansions were announced under the banner of energy security (Greenpeace International, 2023a, pp. iv–v). Global Energy Monitor’s Europe Gas Tracker, cited there, similarly concludes that planned LNG capacity will overshoot plausible demand in a Paris-aligned pathway, creating a risk of stranded assets. From a system-level perspective, this is not an accidental miscalculation but a rational outcome of a governance system in which gas operators design scenarios, propose projects, and then receive EU money to build them.

In conclusion, the critique of regulatory capture in the US–EU LNG build-out rests less on uncovering illegal conduct and more on tracking how institutional design embeds conflicts of interest. ENTSOG’s privileged role in forecasting and planning, GIE’s influence over crisis narratives, and the position of operators like Fluxys at key hubs such as Zeebrugge collectively pull EU energy policy toward continued and expanded reliance on LNG, including from the United States, even as official strategies promise rapid decarbonisation. When infrastructure owners write the scenarios and sit at the planning table, “energy security” can become a code word for securing the value of their own assets rather than aligning with climate and justice goals; thus, REPowerEU illustrates a systemic issue.

References

Corporate Europe Observatory. (2022, May 19). RePowerEU plans misleading and heavily influenced by fossil fuel industry.Nature+7Fossil Free Politics+7European Sources Online+7

Global Witness. (2020). Pipe down: Gas companies’ control over billions in EU funds.Global Witness+2gw.cdn.ngo+2

Greenpeace Belgium. (2025). The LNG trap: Europe’s fossil gas dependence on Russia and the United States.Greenpeace+2Greenpeace+2

Greenpeace International. (2023a). Who profits from war: How gas corporations capitalise on war in Ukraine.Greenpeace+3Greenpeace+3Greenpeace+3

Greenpeace International. (2023b, April 27). Revealed: Gas industry pushing US and Europe into contracts that would roast the planet [Press release].