Energi-, Forsynings- og Klimaudvalget 2016-17
EFK Alm.del Bilag 45
Offentligt
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Consultation on the Oil Stocks Directive (Directive
2009/119/EC)
Fields marked with * are mandatory.
Introduction
This consultation is launched to collect views and suggestions from stakeholders and citizens for the
purposes of the current evaluation of Council Directive 2009/119/EC imposing an obligation on
Member States to maintain stocks of crude oil and/or petroleum products. The general objective of
the evaluation is to assess how the Oil Stocks Directive has been implemented in the Member States
and how it is functioning in practice; to identify possible problems and areas for improvement or
simplification.
Article 22 of the Directive tasked the Commission to "review" (evaluate) the functioning and
implementation of this Directive. As a first step, an independent study was carried out by an external
consultant. The final report is published on the website of the Directorate General for Energy (
https://ec.europa.eu/energy/en/studies ). As a part of this study, a technical survey was carried out
addressed to targeted stakeholders.
For more information about the evaluation, see the
roadmap
Who should answer?
The Commission is now seeking the views of all stakeholders and general public, with the help of a
general non-technical survey, which focusses on the basic questions of the evaluation. Stakeholders
having replied to the technical survey are encouraged to answer to this public consultation, which will
serve as a complement to the input they provided in the past. This consultation also provides experts
the opportunity to express their personal views, which might well differ from the official position of
their institutions / authorities.
What is the Oil Stocks Directive?
In view of the important role of oil for the economy and the significant import dependence, EU
Member States have to hold emergency oil stocks. This obligation was imposed first in 1968, under
Council Directive 68/414/EEC of 20 December 1968. Such stocks shall ensure the continuity of
supply of petroleum products to consumers in case of possible disruptions. In 2009 the legislation
was revised with the following main objectives in mind:
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- improving the availability of the stocks,
- better harmonization with the stockholding system created by the International Energy Agency
(IEA),
- reducing administrative burden
- and improving transparency.
Member States had to transpose the Directive into their national legal order by 31 December 2012.
Main provisions of the Oil Stocks Directive
Member States must maintain a total level of emergency oil stocks corresponding, at the very least, to
90 days of average daily net imports or 61 days of average daily inland consumption, whichever of
the two quantities is greater.
The average daily net imports are to be calculated on the basis of the method explained in Annex I of
the Directive, whilst the procedure for calculating average daily inland consumption is given in Annex
II. Annex III lays down the procedure for calculating stock levels.
The Directive includes several provisions which are supposed to improve the availability of stocks; for
example, it distinguishes emergency stocks and commercial stocks and clarifies that stocks held by
bankrupt companies cannot be reported as emergency stocks. The Directive also introduced the
so-called specific stocks; Member States may make a voluntary commitment to establish such stocks
which have to meet stricter requirements related to their composition and availability. Member States
have an obligation to ensure that emergency oil stocks are available and physically accessible. In this
regard, they are responsible for putting in place arrangements for the identification, accounting and
control of these stocks. A register containing information on emergency stocks (the location of the
depot, refinery or storage facility, the quantities (involved, the owner of the stocks and their nature)
has to be established and continually updated.
Since 2013, a single questionnaire is used by the IEA and the Commission, which was adjusted to
fully meet the requirements of the Directive. In addition to the monthly reporting of stock levels, the
Directive introduced annual reporting (summary copy of the register and a report on the measures
ensuring the availability and physical accessibility of stocks) which provides additional information
about the Member States' stockholding arrangements.
 
CSE
: In order to maintain stocks, each Member State may set up a central stockholding entity (CSE),
in the form of a non-profit making body or service. The CSE shall maintain oil stocks (acquire and
manage these stocks). Under the conditions and limitations laid down by the Directive, CSEs and
Member States may delegate part of the management of stocks to another Member State with stocks
on its territory, to the CSE set up by the said Member State or to economic operators
Specific stocks and other stocks of products:
Each Member State is invited to commit to
maintaining specific stocks. In this case, they must maintain a minimum level defined in terms of
number of days of consumption. Specific stocks shall be owned by the Member State concerned or
the CSE set up by it. Member States shall publish their decision to hold specific stocks in the Official
Journal of the European Union.
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Specific stocks shall be composed of one or several of the following products: ethane; LPG; motor
gasoline; aviation gasoline; gasoline-type jet fuel (naphtha-type jet fuel or JP4); kerosene-type jet
fuel; other kerosene; gas/diesel oil (distillate fuel oil);fuel oil (high sulphur content and low sulphur
content); white spirit and SBP; lubricants;bitumen; paraffin waxes; petroleum coke.
Member States shall ensure that in total, for the reference year, the crude oil equivalent of the
quantities consumed of products included in the categories used is at least equal to 75 % of inland
consumption. If there is no commitment to maintain at least 30 days of specific stocks, Member
States shall ensure that at least one third of their commitment is held in the form of products, under
the conditions laid down by the Directive.
 
Biofuels and additives:
When calculating stockholding obligations and stock levels actually
maintained, biofuels and additives shall be taken into account only where they have been blended
with the petroleum products concerned. Furthermore, under certain conditions, part of the biofuels
and additives stored on the territory of the Member State in question may be taken into account when
calculating stock levels actually maintained.
Emergency procedures: Member
States must be able to release all or part of their emergency
stocks and specific stocks if required. Contingency plans shall be developed. In the event of a major
supply disruption, emergency procedures must be in place. Specific rules also apply according to
whether or not there is an effective international decision to release stocks.
Finally, the Directive set up a "Coordination Group for oil and petroleum products" (Article 17). While
the main role of the Group is to facilitate coordination between Member States in case of a disruption,
it is also a useful forum to discuss various issues related to the implementation of the Directive.
See more information about the EU stockholding system at
https://ec.europa.eu/energy/en/topics/imports-and-secure-supplies/eu-oil-stocks
http://ec.europa.eu/eurostat/data/database 
 
IEA regime
Each IEA country has an obligation to hold oil stocks equivalent to no less than 90 days of net
imports. No obligation is imposed to countries that are net oil exporters. The oil stocks obligation can
be met through stocks held exclusively for emergency purposes and also to stocks held for
commercial or operational use, including stocks held at refineries, port facilities and in tankers in
ports. In case of oil disruption, the IEA may activate collective emergency oil response measures.
IEA has 29 member countries. 20 EU Member States are also parties to IEA.
See more information on the IEA stockholding system at
http://www.iea.org/media/freepublications/security/EnergySupplySecurity2014_PART1.pdf
https://www.iea.org/netimports/
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 1. General information about respondents
*
1.1. Are you answering on behalf of an organisation or institution?
Yes, I am answering on behalf of an organisation or institution
No, I am answering as an individual
*
1.2. If replying as an individual/private person, please give your name; otherwise give the name of your
organisation, your full name and position title.
Text of 1 to 200 characters will be accepted
*
1.3.Please enter your email address:
[email protected]
*
1.4. In which capacity are you completing this questionnaire?
as an individual / private person
civil society organisation
private enterprise
public authority
consumers association
academic/research institution
international organisation
professional organisation
public enterprise
other
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*
please specify here:
50 character(s) maximum
Danish Ministry of Energy, Utilities and Climate
1.5. If you are a private or public enterprise, could you please indicate your principal business sector?
Central Stockholding Entity
Oil storage
Oil trading
Transport
Oil processing
Oil transportation
Chemicals
other
*
please specify here:
50 character(s) maximum
1.6. If you are a private or public enterprise, could you please indicate the size of your company?
(Medium-sized enterprise: an enterprise that employs fewer than 250 persons and whose annual
turnover does not exceed EUR 50 million or whose annual balance-sheet total does not exceed EUR
43 million. Small enterprise: an enterprise that employs fewer than 50 persons and whose annual
turnover and/or annual balance-sheet total does not exceed EUR 10 million. Micro-enterprise: an
enterprise that employs fewer than 10 persons and whose annual turnover and/or annual
balance-sheet total does not exceed EUR 2 million.)
large enterprise
medium-sized enterprise
small enterprise
micro-enterprise
I don't know
1.7 If you are a private or public enterprise, could you please indicate whether you are obliged to hold oil
stocks?
Yes
No
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1.8. If you are a professional organisation, which sector(s) does your organisation represent?
Oil processing
Oil transportation
ChemicalsTransport
Oil storage
Oil Import-export
other
please specify here:
50 character(s) maximum
1.9. If you are a professional organisation, where are your member companies located? (several
answers are possible)
Austria
Cyprus
Finland
Hungary
Lithuania
Poland
Slovenia
non-EU country(ies)
1.10. If you are a civil society organisation, please indicate your main area of focus.
Energy
Environment & Climate
Technology & Research
other
please specify here:
50 character(s) maximum
Belgium
Czech Republic
France
Ireland
Luxembourg
Portugal
Spain
Bulgaria
Denmark
Germany
Italy
Malta
Romania
Sweden
Croatia
Estonia
Greece
Latvia
Netherlands
Slovakia
United Kingdom
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1.11. If you are a public authority, can you define more specifically your area of competence?
national government
national parliament
regional government
regional parliament
local authority
governmental agency
EU institution / body
other
please specify here:
50 character(s) maximum
1.12. Is your organisation registered in the 
Transparency Register
?
Yes
No
Please give your Register ID number
(nb. If your organisation/institution responds without being registered, the Commission will consider its
input as that of an individual and will publish it as such.)
200 character(s) maximum
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1.13. Please give your country of residence/establishment
Austria
Cyprus
Finland
Hungary
Lithuania
Poland
Slovenia
Other non-EU European
country
Belgium
Czech Republic
France
Ireland
Luxembourg
Portugal
Spain
Non-European
country
Bulgaria
Denmar
k
German
y
Italy
Malta
Romani
a
Sweden
Croatia
Estonia
Greece
Latvia
Netherlands
Slovakia
United
Kingdom
*
please specify here:
50 character(s) maximum
*
1.14. Please indicate your preference for the publication of your response on the Commission’s website:
(Please note that regardless the option chosen, your contribution may be subject to a request for access
to documents under Regulation 1049/2001 on public access to European Parliament, Council and
Commission documents. 
http://ec.europa.eu/transparency/access_documents/index_en.htm
  In this
case the request will be assessed against the conditions set out in the Regulation and in accordance
with applicable data protection rules.)
Under the name given: I consent to publication of all information in my contribution and I
declare that none of it is subject to copyright restrictions that prevent publication.
Anonymously: I consent to publication of all information in my contribution and I declare that
none of it is subject to copyright restrictions that prevent publication.
Please keep my contribution confidential. (it will not be published, but will be used internally
within the Commission)
2. Relevance
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Relevance looks at the relationship between the needs and problems in society and the objectives of
the intervention. The economic, social or political climate may change over time which could make a
previous intervention less relevant. In this context, is it still relevant to stipulate minimum
requirements for emergency oil stocks and/or to align those requirements to those of the International
Energy Agency (IEA)?
2.1 Do you agree that the emergency oil stocks are necessary to guarantee the security of supply in the
EU?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
Security of supply has high priority due to the dependency on oil products in the EU. Release of stocks is
an effective way to assist a tight market.
2.2 Do you agree that the EU needs to have its own rules on emergency oil stocks?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
The EU has a stronger need for oil products than the IEA and is therefore in need of requirements
about the composition of oil stocks in order to meet the actual needs during a crisis.
2.3 Do you agree that the EU rules on emergency oil stocks need to be in line with the rules applied in
the context of the IEA?
Yes, fully
Yes, partly
No
No opinion
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Please explain your answer
200 character(s) maximum
There is a need to deviate because of the different composition of member states and different
need for oil products.
2.4. The Directive obliges to hold a level of oil stocks equivalent to 90 days of average daily net imports
or 61 days of average daily inland consumption, whichever of the two quantities is greater. In your
view, are these levels of emergency oil stocks requested by the Directive appropriate for the EU to
cope with a serious oil supply disruption?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer notably by clarifying if you think higher or lower level of stocks would be
more adapted.
200 character(s) maximum
Further analysis would be advantageous to clarify this incl. analysis of the risk, the economic consequences
of an oil crisis, the effect of the common preparedness, and the costs of emergency stocks.
2.5. The average daily net imports referred to in question 2.3. need to be calculated based on the crude
oil equivalent of imports during the previous year. Annex I of Directive 2009/119/EC lays down the
methodology based on which the imports of petroleum products are converted into crude oil equivalent.
In your view, is this methodology well adapted for the calculation of the equivalent of crude oil import?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
Annex 1 is for MS with netto import. DK applies Annex 2.
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2.6. The average daily inland consumption referred to in question 2.3 need to be calculated based on the
crude oil equivalent of inland consumption during the previous calendar year. Annex II of Directive
2009/119/EC lays down the methodology based on which the inland consumption is converted into
crude oil equivalent of inland. In your view, is this methodology well adapted for the calculation of the
inland consumption?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
To clarify this issue an analysis of the need for all the mentioned oil products within the EU could be beneficial
in order to ensure that the obligation is covered with consumed products.
2.7. Annex III of Directive 2009/119/EC lays down the methodology for calculating the level of stocks
held. In your view, is this methodology well adapted for calculating the actual level of stocks that would
be actually accessible and available in case of oil supply disruption?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
Reference is made to the answer to question 7.4 and 7.5.
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2.8. Any additional views related to the relevance of the objectives of Directive 2009/119?
500 character(s) maximum
3.  Effectiveness
Effectiveness analysis considers how successful EU action has been in achieving or progressing
towards its objectives. The evaluation should form an opinion on the progress made to date and the
role of the EU action in delivering the observed changes. Directive 2009/119 aimed at: (1) improving
the availability of the stocks, (2) better harmonizing with the stockholding system created by the IEA,
(3) reducing administrative burden and (4) improving transparency.  In this context , to what extent
have the 4 main objectives been achieved? To what extent have the planned results been produced
and contributed to the overall objective of strengthening the security of oil supply?
3.1. In your view, has the Directive improved the availability of the stocks in case of oil disruption?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
The centrally controlled stocks and the monthly statistical reporting are assumed to improve the availability
of stocks.
3.2. In your view, has the Directive improved the physical accessibility of the stocks in case of oil
disruption?
Yes, fully
Yes, partly
No
No opinion
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Please explain your answer
200 character(s) maximum
It is assumed that the definition of physical accessibility in the Directive is helpful to ensure the physical
accessibility.
3.3. In your view, has the Directive achieved a better harmonization with the International Energy Agency
(IEA) system?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
Reference is made to the answer of question 2.3
3.4. If you are a public administration, how would you rate the impact of the Directive on the
administrative burden?
The administrative burden increased largely
The administrative burden increased slightly
No impact
The administrative burden decreased slightly
The administrative burden decreased largely
No opinion
Please explain your answer
200 character(s) maximum
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3.5. If you are an economic operator, how would you rate the impact of the Directive on the
administrative burden?
The administrative burden increased largely
The administrative burden increased slightly
No impact
The administrative burden decreased slightly
The administrative burden decreased largely
No opinion
Please explain your answer
200 character(s) maximum
3.6. In your view, has the Directive improved the transparency as regards the level of emergency oil
stocks held in the Member States and the European Union as a whole?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
The distinction between emergency and commercial stocks in the Directive are assumed to have a positive
effect on the transparency of stocks.
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3.7. Emergency oil stocks may be held at any location across the EU. The previous rules allowed
cross-border stockholding only if there was a bilateral agreement between the Member States
concerned. The Directive removed this requirement, but Member States need to authorize in advance
cross-border arrangements between operators. In your view, has the Directive improved transparency
as regards the cross border stocks?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
It could be considered to assess the possibilities for a common auditing system (information sharing)
regarding stocks held abroad to ensure full transparency.
3.8. Are you aware of any unexpected or unintended effects of the Directive?
Yes
No
Please explain your answer
200 character(s) maximum
In case of bankruptcy the benefit of protecting the availability of the oil stocks is limited by the fact that
stocks held by bankrupt obliged companies cannot be reported as emergency stocks.
3.9. Any additional views on the effectiveness of Directive 2009/119?
500 character(s) maximum
Provisions about biofuels could be clearer in order to be able to impose an obligation for instance for
production or import of biofuels.
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 4. Efficiency
Efficiency considers the relationship between the resources used by an intervention and the changes
generated by the intervention. Efficiency analysis will include analysis of administrative and regulatory
burden and look at aspects of simplification. It is important to note that efficiency analysis should
always look closely at both the costs and benefits of the EU intervention as they accrue to different
stakeholders.
The ex-ante cost benefit carried out by the Commission in 2008 can be consulted in the Impact
Assessment
4.1. In your view, the costs related to the implementation of the Directive were:
Very high
high
Moderate
Low
No opinion
Please explain your answer
200 character(s) maximum
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4.2. How would you estimate the economic burden resulting from the Directive on the different
stakeholders? (0 stands for no impact 1 for minimum impact and 5 for a maximum impact)
0
1
2
3
4
5
CSE
SME
Industry
Consumers
Tax payers
State finance
4.3. Did the Directive improve efficiency by simplifying reporting?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
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4.4. Did the Directive improve efficiency through better harmonisation with the IEA system?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
Alignment with the IEA has made it possible to improve the EU contribution to an
IEA collective action. Reference is made to the answer to question 2.3.
4.5. Considering your answers to chapter 3 and to questions 4.3 and 4.4, do you think that the costs
related to the implementation of the Directive are proportionate to the benefits achieved?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
4.6. Any additional views on the effectiveness of Directive 2009/119?
500 character(s) maximum
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 5. Coherence
The evaluation of coherence involves looking at a how well or not different actions work together.
Checking "internal" coherence means looking at how the various internal components of an EU
intervention operate together to achieve its objectives. Similar checks can be conducted in relation to
other "external" interventions, at different levels: for example, between interventions within the same
policy field or in areas which may have to work together. At its widest, external coherence looks at
compliance with international agreements/declarations.
5.1. The IEA requires its members to hold oils stocks equivalent 90 days of net imports and imposes no
obligation on net oil exporters. Contrary to the EU system, stocks held for commercial or operational
use can be counted to this purpose. 20 EU Member States have to comply with both the EU and the
IEA mechanism. In your view, is the system resulting from the Directive coherent with IEA obligations?
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
There is no need to be fully coherent with the IEA system due to the different context and composition of
MS, refinery capacity etc. Reference is made to question 2.3
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5.2. The Energy Union means making energy more secure, affordable and sustainable. The Energy
Union strategy is made up of 5 dimensions: (1) energy security, solidarity and trust; (2) a fully
integratedEuropean energy market; (3) energy efficiency contributing to moderation of demand; (4)
decarbinising the economy and (5) research innovation and competitiveness. 
http://ec.europa.eu/priorities/energy-union-and-climate_en
 In your view, is the Directive coherent with the Energy Union objectives?
 
Yes, fully
Yes, partly
No
No opinion
Energy security, solidarity and
trust
Fully integrated European
energy market
Energy efficiency contributing to
moderation of demand
Decarbonising the economy
Research, innovation and
Competitiveness
Please explain your answer
200 character(s) maximum
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5.3. In your view, is the Directive coherent with other EU rules in the energy sector ?
https://ec.europa.eu
/energy/en/topics
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
5.4. In your view, is the Directive coherent with other EU rules relating to the oil sector?
https://ec.europa.eu/energy/en/topics/oil-gas-and-coal
http://ec.europa.eu/growth/tools-databases/newsroom/cf/itemdetail.cfm?item_id=8630&lang=en
Yes, fully
Yes, partly
No
No opinion
Please explain your answer
200 character(s) maximum
5.5. In your view, is the Directive coherent with other EU policies?
https://ec.europa.eu/info/index_en
Yes, fully
Yes, partly
No
No opinion
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Please explain your answer
200 character(s) maximum
5.6. Any additional views on the coherence of the Directive with other rules, policies and actions?
500 character(s) maximum
 6. EU added value
European added value is defined as the value resulting from an EU intervention which is additional to
the value that would have been otherwise created by Member State action alone. In the context of the
evaluation, the question is whether having an EU Directive on emergency oil stocks presents more
added value than a situation without EU intervention.
6.1. Do you see an added value in having a coordinated mechanism for emergency oil stocks?
Yes
No
No opinion
6.2. Do you think that the existence of a separate EU system for emergency oil stocks is justified?
Yes
No
No opinion
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Please explain your answer
200 character(s) maximum
Due to the markets global character a disruption will affect all MS. The objecticves of the Directive can
best be optained through cooperation, common requirements and solidaity between MS.
6.3. Do you consider that the EU system is a good complement of the IEA system?
Yes
No
No opinion
Please explain your answer
200 character(s) maximum
IEA has internationally recognized rules. However, the EU has a need to adapt the rules to the
European context. Reference is made to the answer to question 2.2.
6.4. What would be the consequences on the levels of oil stocks available in case of disruption if the EU
no longer required Member States to hold emergency stocks?
No consequence
Decrease the level of oil stocks held
No opinion
Please explain your answer
200 character(s) maximum
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6.5. What would be the consequences on the security of oil supply if the EU no longer required Member
States to hold emergency stocks?
No consequence
Increase the vulnerability in case of oil disruption
No opinion
Please explain your answer
200 character(s) maximum
Reference is made to the answer to question 6.2.
6.6. Is there a need for EU additional policy on emergency oil stocks?
Yes
No
Please explain your answer
200 character(s) maximum
6.7. Any additional views on Directive 2009/119 added value?
500 character(s) maximum
7. Results of the study – Recommendations
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A study in support of the mid-term evaluation of the functioning and implementation of Council
Directive 2009/119/EC was prepared by a consultant to provide the Commission with an independent
evaluation of the Directive. Respondents are invited to give their opinion on the findings and
recommendations presented in the report[1].
The composition and levels of emergency stocks held are crucial to addressing a disruption in an
effective way. Annex I of the Directive sets out the methods and procedures for the calculation of the
crude oil equivalent of the petroleum product imports. Annex II sets out the method for calculating the
crude oil equivalent of inland consumption. Annex III sets out the methods for calculating the level of
stocks held. The methods and procedures described in these Annexes may be amended in
comitology, in accordance with the regulatory procedure referred in Article 23(2).
Naphtha is a petroleum product which can also have a petrochemical use. Annex I and Annex II
detailed specific provisions to take into account the part of naphtha not available for energy purposes.
Annex I states that the crude oil equivalent of oil import is reduced by 4%, or if by the net actual
consumption or the average naphtha yield if greater than 7% on the national territory of the Member
State. Annex III state that crude oil stocks are to be reduced by 4% which correspond to the average
naphtha yield, and stocks of naphtha are not included in the emergency stocks.
 
[1] Study in support of the mid-term evaluation of the functioning and implementation of Council
Directive 2009/119/EC- Trinomics, 2016- http
7.1. The 7% naphtha threshold might have an impact on the stockholding obligation for some Member
States with naphtha yield fluctuating around 7%. Do you consider annex I should be amended to limit
the trigger effect of the 7% naphtha yield?
Yes
No
Please explain your answer
500 character(s) maximum
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 EFK, Alm.del - 2016-17 - Bilag 45: Høringssvar om evaluering af olielagerdirektiv
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7.2. Under the IEA methodology, for calculating the stock levels, the 4% naphtha yield is deducted from
"crude oil, NGL, and feedstock" which is the abbreviation for the full name of Crude, NGL, Feedstocks,
Additives/oxygenates and Other Hydrocarbons; compared to 4% reduction of “crude oil” in Annex III of
the Directive. “Crude oil” in the sense used in Annex III of the Directive comprises also Crude, NGL,
Feedstocks, Additives/oxygenates and Other Hydrocarbons. Do you consider Annex III of the Directive
should be amended to explicitly indicate the full name of Crude, NGL, Feedstocks,
Additives/oxygenates and Other Hydrocarbons?
Yes
No
Please explain your answer
500 character(s) maximum
7.3. Under the IEA methodology, naphtha for gasoline production is included in the calculation for stock
levels if it is reported as gasoline blending component while naphtha for petrochemical uses is
excluded. According to Annex III of the Directive, stocks of naphtha are not included in the emergency
stocks. Do you consider Annex III of the Directive should be amended to further detail the possible
reporting of naphtha as gasoline blending component?
Yes
No
Please explain your answer
500 character(s) maximum
Both in the IEA methodology and in Annex III of the Directive, a 10% deduction is made on the
quantities of stocks calculated. According to the IEA methodology the deduction is made to account
for unavailable stocks. The Directive does not specify any reason for the deduction.
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 EFK, Alm.del - 2016-17 - Bilag 45: Høringssvar om evaluering af olielagerdirektiv
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7.4. In your view, is a 10% deduction still justified?
Yes
No
Please explain your answer
200 character(s) maximum
The "tank bottoms" argument seems to be technologically outdated. Reference is made to the answer to
question 2.4 as the 10 percent deduction is part of the preparedness level.
7.5. if not justified, how should Annex III be amended?
No deduction rate at all for unavailability
A lower deduction rate
Several deduction rates based on the nature of the stock holders (whether CSE, private, cross
border,…)
Other (specify)
Please explain your answer
200 character(s) maximum
An amendment in favour of CSE's would improve the incentive to have more CSE-held stocks. Reference
is made to the answer to question 3.1.
Additional contribution
Do you have other specific views that could not be expressed in the context of your replies to the above
questions?
5000 character(s) maximum
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 EFK, Alm.del - 2016-17 - Bilag 45: Høringssvar om evaluering af olielagerdirektiv
Finally, you may upload here any relevant documents, e.g. position papers, that you would like the
European Commission to be aware of.
Thank you for your participation in the consultation!
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