After a five-month delay, the European Commission published its much-touted action plan on May 6 to end its remaining dependence on Russian fossil fuels and nuclear products by the end of 2027. 

The deadline aligns with the provisions of REPowerEU, a package of measures launched immediately after Russia’s full-scale invasion of Ukraine in 2022, designed to save energy, increase renewable output, and diversify away from Russian fossil fuels. 

At first glance, provisions are more radical than initially anticipated.

Earlier discussions hinted merely at the possibility of enabling buyers to claim force majeure to terminate contracts without incurring penalties. 

The latest measures go much further and propose:

• A ban on imports of Russian gas under new contracts and existing spot contractsby the end of this year. 
• Supplies under long-term contracts to end by 2027. 
• Member states plan and monitor the phase-out of Russian nuclear energy imports through national plans, with clear actions and timelines.
• EU countries have until the end of 2025 to draft similar phase-out planswith clear actions and timelines for replacing Russian oil by the end of 2027.
• The continuation of sanctions on entities and vessels transporting oil suspected of illicit activities.

If properly implemented, the plan could deal a blow to Russia’s ability to use the energy weapon to blackmail Europe while denying it billions of dollars to replenish its war chest. 

Nevertheless, their effectiveness, particularly with regards to natural gas imports, will depend on enforcement and member states’ commitment to implement the rules. 

This is where things get trickier.

Since 2021, Russia’s share of the EU’s total gas imports (pipeline and liquefied natural gas, or LNG) fell from 45% in that year to 19% in 2024, and is expected to drop further to 13% after Ukraine refused to renew a new transit agreement at the beginning of 2025. 

For oil, the share shrunk even more dramatically from 27% at the beginning of 2022 to 3% now. 

However, the steep decrease for gas was triggered not by the EU but Russia itself as it sought to blackmail Europe and undermine its support for Ukraine. 

To phase out the last remaining oil and gas imports, the EU will have to rely on member states, and, especially, on those still importing the fuels to track, monitor and report the imports. 

Awkwardly enough, pipeline gas is imported by or via countries such as Hungary, Slovakia, and Bulgaria, whose governments have been more eager to please the Russian regime than EU officials. 

Under further rules to be unveiled in June, the Commission will ask companies to provide information related to volumes and duration of Russian gas contracts. 

Data will be reported to national authorities such as customs, national energy and security authorities and to the Commission. 

While the EU is right to demand improved transparency, introducing monitoring and traceability requirements, it’s unclear who will provide certification of the gas molecules.

The remaining pipeline gas imports enter the EU via Turkey, a country outside the bloc’s jurisdiction that barely produces transparent information for its own domestic gas market, let alone to comply with EU rules. 

Since 2023, it has facilitated either the additional transit of Russian gas to the EU or access to volumes whose origin remains questionable. 

Last year, Russian gas transit via Turkey increased 31% compared to 2023 but Ankara also facilitated the export of another 2bn cubic meters (bcm) of gas whose origin cannot be accounted for, according to official data.

Although it cannot be conclusively shown that the 2bcm was Russian, many traders say it was sold at heavily discounted prices, which only a big producer such as Russia could have been in a position to offer. 

Without verifiable certification in Turkey, which imports gas from a variety of sources, it will be difficult to guarantee the non-Russian origin of the molecules entering Europe. 

As a matter of fact, instead of working with the EU to create a joint certification scheme, Turkey is keen to expand its lucrative and non-credible “Turkish gas” exports — local production is tiny and covers less than 5% of its total demand, according to official regulator reports. 

Within minutes of the EU publishing its Russian phaseout roadmap, the Romanian minister Sebastian Burduja said he had signed a memorandum of understanding with his Turkish counterpart for the import of “Turkish gas”. 

Many companies keen to secure discounted Russian gas have found creative ways to hide its origin, claiming it was sourced in other countries, such as Azerbaijan. 

There is a real risk that buyers with large portfolios including liquefied natural gas could import Russian gas or LNG and sell it under a different label. The EU’s latest roadmap refers to such swap practices in passing but does not outline concrete steps on how to stamp them out. 

Furthermore, the action plan does not bar EU companies partnering with Russian entities in energy production. 

Earlier in March, Russian oil and gas producer LukOil said it would resume gas exploration in the Romanian offshore section of the Black Sea along with minority partner Romgaz, the local state producer. 

How would such partnerships be viewed under the latest roadmap?

If Romania, supposedly a pro-EU country, turns to Turkey for gas imports which may well originate in Russia, or allows Russian entities to re-enter the EU through the backdoor, what could be expected from Kremlin-friendly countries such as Hungary? 

Hungary, like neighboring Slovakia, chooses to depend on Russian imports for most of its gas consumption and has made a habit of opposing any measures that could harm Moscow’s interests. 

Without committed enforcement and hefty penalties for potential breaches implemented across all member states, it’s questionable the EU’s latest rules would stick.

The Commission has taken a step in the right direction, but it will take much sharper tools to turn intention into action.  

Dr. Aura Sabadus is a senior energy journalist writing for Independent Commodity Intelligence Services (ICIS), a London-based global energy and petrochemicals news and market data provider. She is also a Non-resident Senior Fellow with the Democratic Resilience Program at the Center for European Policy Analysis (CEPA). 

Europe’s Edge is CEPA’s online journal covering critical topics on the foreign policy docket across Europe and North America. All opinions expressed on Europe’s Edge are those of the author alone and may not represent those of the institutions they represent or the Center for European Policy Analysis. CEPA maintains a strict intellectual independence policy across all its projects and publications.

Ukraine 2036

How Today’s Investments Will Shape Tomorrow’s Security

Read More

CEPA Forum 2025

Explore CEPA’s flagship event.

Learn More