In June, the European Union approved a new package of sanctions aimed at Vladimir Putin’s regime to curb its revenues and hinder financing for its military invasion of Ukraine. Among the measures was a ban on reexporting liquefied natural gas shipped from the EU. Member states, including Spain, may allow energy companies to resell Russian LNG to other European countries, but not to third countries outside the Union.
Spain, which has become a leading global gas trading hub since the energy crisis disrupted markets, moved ahead this summer with a tracing system designed to track all Russian gas imported to prevent its reexport outside the EU and to comply with the new rules.
Member states have until the end of the year to design how the restrictions on reexport will be applied, but Spain has stepped forward five months ahead of that deadline. Enagás, the operator of Spain’s gas system and the national network of pipelines and regasification plants, notified all market players on August 12 about how the restrictions would be applied and the date when they would take effect.
Since then, the government and Enagás have not detected any illegal reexports of Russian gas, nor have they issued a general prohibition on reexports from the country’s extensive plant network. Officials familiar with the tracing system reported that no reexports have been necessary to curb, and that all marketers are complying with the sanctioned rules.
The Ministry for the Ecological Transition, led by Vice President Teresa Ribera, and Enagás collaborated to design and implement a method to trace all gas from Russia and block shipments to non-EU destinations. Spain will not apply the general ban on reexports until March 26, 2025 for all resale contracts signed before the June approval, but the tracing system is already active for agreements signed after that date.
Gas companies intending to load LNG onto ships in Spain for reexport outside the Union must prove that the gas origin is not Russian and must provide Enagás with precise and complete information about its provenance as described in the official implementation documentation.
When a gas utility plans to market gas by LNG ships from Spain to destinations outside the EU, it must show that in the preceding fifteen days it has unloaded at Spanish plants a quantity of non-Russian origin equal to or greater than the amount to be resold. Enagás notes that shipments lacking clear origin documentation will be denied until provenance is fully verifiable.
Russian gas arriving in Spain
Spain remains one of Russia’s major suppliers and has, year to date, risen to the position of the second-largest supplier after Algeria, accounting for more than 21 percent of total imports, according to Enagás and the Strategic Reserves Corporation data.
Spain has become a principal recipient of Russian gas by sea, subsequently reexporting it to other countries. With the European pipeline link from Russia to Europe largely paused, Spain has positioned itself as a key destination for Russian gas by ship, leveraging its large regasification capacity to supply various markets across the continent.
Spain’s gas system has evolved into a unique model that effectively treats the entire regasification network as a single, centralized storage. The country operates a large, integrated system where gas flows are managed as one pool rather than isolated assets, enabling rapid responses to supply and demand shifts.
All gas entering Spain by pipeline or ship is treated as part of a common pool, allowing a company to draw that same volume for resale at another plant or through another gas outlet, even across long distances. This model makes tracing the origin of Russian gas more challenging when it comes to blocking reexports outside Europe.
In other countries, the seller and buyer typically arrange delivery at the same regasification plant. Spain employs the tank grouping approach, which allows a ship to unload at a plant in Galicia and enables another company to take the same quantity at the Barcelona plant, or for gas to enter via Sagunto (Valencia) and then be traded through the Spain-France gas corridor. This arrangement helps the system and marketers adjust supply and demand swiftly in response to geopolitical events, weather variations, or vessel delays. During the energy crisis, operating as a gigantic storage facility gave Spain an advantage over other nations, boosting energy security and elevating the country to a major gas trading hub. Under the new restrictions, energy companies must prove that the gas being resold did not originate in Russia and that it entered Spain through any regasification facility.