The comparability game that natural gas sellers cannot afford to lose
The context: a new “downstream” carbon market
The new phase of European climate policy starts from daily consumption. No longer just large industrial plants, but buildings, road transport and civil uses.
With the revision of Directive 2003/87/EC of 13 October 2003, amended by Directive (EU) 2023/959 of 10 May 2023, ETS2 takes shape, the second European greenhouse gas emission allowance trading system. A mechanism designed to extend carbon pricing to sectors previously less exposed.
The scope is precisely defined and includes combined heat and power production and thermal plants (CRF 1A1a ii and iii), road transport (CRF 1A3b, excluding agricultural vehicles on paved roads), the commercial and institutional sector (CRF 1A4a), residential (CRF 1A4b), as well as energy industries (CRF 1A1, with specific exclusions) and the manufacturing and construction sector (CRF 1A2).
After a significant political delay, the operational start is set for 2028. However, the preparatory phase is already underway from 2025 and it is precisely in this phase that the balances of the new system are being defined.
The difference compared to the traditional ETS is substantial: the mechanism acts upstream in the supply chain. Fuel suppliers — including natural gas — become obligated parties to purchase emission allowances. Costs will inevitably be passed along the chain to the final customer.
The economic issue: “high quotas” and cost transfer
The operation is typical of cap-and-trade systems: one allowance for each ton of CO₂, an overall emissions cap that progressively decreases over time, and an auction system without free allocations.
From 2029, with reference to 2028 emissions, ETS2 costs may be passed on to final customers, directly impacting natural gas bills.
This is where the price changes nature. To the raw material component and commercial margin is added the carbon cost, destined to become an increasingly relevant variable.
The critical issues are already evident: CO₂ price volatility makes the final cost less predictable, price construction becomes more complex and less transparent, while the reputational risk grows for sellers called to justify increasingly complex increases.
The real paradigm shift: the data
If the price becomes complicated, it is because the management of information changes.
From 2025, natural gas sellers must monitor emissions associated with fuels placed on the market, collect data on final use according to CRF categories, and annually report verified emission data by April 30.
The regulatory reference is Implementing Regulation (EU) 2023/2122, which amends Implementing Regulation (EU) 2018/2066.
The CRF (Common Reporting Format) system requires assigning each consumption to a precise emission category. And it is precisely this step that makes the operational framework complex: the seller does not directly control how the gas is used. They must therefore rely on declarative information or equip themselves with tools capable of precise measurement.
The shift from estimation to measurement becomes, in fact, a strategic issue.
Smart meter: from operational technology to competitive lever
In this scenario, advanced smart meters change function. They are no longer simple remote reading tools, but systems capable of profiling consumption, distinguishing usage destinations — heating, production processes, self-propulsion — and integrating data from IoT devices and building management systems.
The difference is concrete. Without granular data, the risk of incorrect classifications increases, with possible sanctions or overestimations of emissions. It becomes difficult to demonstrate possible exclusions, such as non-energy uses, and pricing loses transparency, becoming difficult to defend commercially.
With reliable data, instead, a competitive space opens: certifiable traceability, reduced ETS2 risk, and the possibility to build offers consistent with actual consumption.
The real game: offer comparability
It is on this ground that the most relevant game is played.
The introduction of ETS2 risks creating a two-speed market. On one side, offers in which the CO₂ cost is incorporated without clear separation, making it difficult for the customer to distinguish between gas price and emission component. In this scenario, the risk of opacity and “tariff greenwashing” is real.
On the other side, a model based on transparency, where price components are made explicit. Natural gas and CO₂ follow distinct logics and become comparable through clear indicators, such as €/Smc and kgCO₂/Smc.
The difference is not only technical: it is a matter of trust and competitive positioning.
The strategic risk for gas sellers
The regulatory framework is already defined and assigns suppliers the responsibility for compliance: monitoring, data quality, and communication accuracy.
Underestimating ETS2 means exposing oneself to a series of concrete risks. Margins can be eroded by carbon costs not managed effectively, pricing can lose competitiveness, regulatory exposure increases, and customer trust, increasingly sensitive to price transparency, is undermined.
But the deepest risk is another: the loss of the ability to differentiate in a market that is no longer a simple commodity.
From commodity to information service
With ETS2, natural gas enters a new phase. Value is no longer played only on supply, but on the ability to interpret and make data readable.
Transparency, information quality, and technology — starting from smart meters — become structural elements of the offer.
The challenge is not to avoid the “high quotas”, but to make them understandable, comparable, and sustainable.
Because in 2028 the customer will not choose only the gas price, but who can explain it clearly and transparently.
