The current negotiations around EU/US methane regulations are being sold to the public based on a major unproven assumption which is being repeated by many of the largest “green” NGOs in Europe and the US.
The Assumption: There is already more than enough natural gas (methane) produced in the U.S. that has emissions below the proposed EU limits of 0.2% of produced gas.
There is no peer reviewed science to back up this claim and all of the peer reviewed basin-level emissions data shows much higher emissions than would be required for the EU standards. The most recent data from MethaneSAT on Permian basin emissions showed over 3% for the Texas Permian and just over 1% for the New Mexico Permian, a level which was described as “appreciably high.” However, that 1% emissions level is also the reality in the Appalachian (0.9%) and Haynesville (1.0%) gas plays in the U.S. So if all of the major gas producing basins have “appreciably high” methane emissions, where is the 20% of U.S. gas that is certified to be below 0.2%?
We are asked to believe that 20% of U.S. gas is at or below 0.2% emissions with no proof. EQT, a leading gas producer in the U.S. claims their methane emissions from gas production were 0.007% in 2024. What they don’t offer is peer-reviewed science showing how they did this. If EQT can do this shouldn’t the industry be clamoring to verify, publish and duplicate those results? The lack of scientific evidence to back up their audacious claims is telling. We look forward to some peer-reviewed publications to verify these claims of what appears to be accomplishing what has been impossible for the oil and gas industry to accomplish in its 150 year history.
The following analysis reviews what is known about how we arrived at this point in the regulatory process and indicates that there appears to be a coalition of U.S. non-profit organizations working with U.S. gas producers and various non-profit and for-profit methane emissions tracking and certifying organizations to push the concept of “low emissions US natural gas” when there is no scientific evidence that this gas exists. Members of this coalition are actively pushing for the expansion of U.S. gas production and to increase U.S. LNG exports when the science is clear we must stop expanding oil and gas production and consumption. This is particularly troubling when current clean energy technologies (solar, storage, wind) are producing electricity for significantly lower costs than those for importing LNG for power production. Advocating for fossil fuel expansion in 2025 is in direct conflict with the science of climate change.
The following overview provides information on the “Trace and Claim” concept gaining traction in the EU as a preferred methodology for tracking methane emissions from US production.
The Trace and Claim concept was designed as an alternative to the more popular Book and Claim proposal under which Europeans would buy gas from a supplier and then buy attribute credits (representing the monitoring and emissions standards required by the EU) from a company producing EU compliant gas. The highest profile emissions certifier in the world, MiQ, manages a Book and Claim registry. Under a Trace and Claim system, oil and gas companies would have to disclose their emissions every time the gas changes hands which would be recorded in a digital registry. Importers would have to demonstrate a plausible chain of custody for the gas they import to determine its emissions. Neither plan can actually demonstrate that gas imported into the EU was produced in an EU compliant manner, only that the gas could have been.
Most of the organizations in this document will be familiar to readers (e.g. Clean Air Task Force (CATF), EQT, KPMG, Microsoft) but the document introduces information on a company that has flown under the radar while playing a direct role in the EU regulatory process: Context Labs.
Context Labs has been active for over a decade. Founded in 2016 by Dan Harple, a former MIT professor, the company has provided emissions data services to many large companies including KPMG and Dell. The company’s oil and gas clients include Williams and EQT, the one of the largest gas exporters in the U.S. One of the companies primary services is automating their client’s filing to the Greenhouse Gas Reporting Program, the U.S.’s notoriously inaccurate emissions inventorying system for large facilities
A timeline of relevant events from the past year.
- February 2025: CATF released a report introducing the Trace and Claim concept.
- March 2025: Context Labs launched the Open Decarbonization Project. The press release included quotes from CATF and EQT (largest gas producer in the US). Context Labs is a for profit company. EQT is a Context Labs client.
- May 2025:CATF hosted a closed door round table discussion on developing “credible differentiated fossil fuel markets.”
From CATF’s press release “The workshop agenda included sessions led by the European Commission, the IEA, and major oil and gas stakeholders, including Williams Companies, EQT Corporation, Jonah Energy and Cheniere, non-governmental standards bodies such as the North American Energy Standards Board, as well as technology providers such as Context Labs and Attributes.” - June 2025: CATF released a letter to the EU advocating for protecting the methane regulations. The letter includes a section on supply chain reporting
- August 2025: Context hosted a webinar that included Microsoft and gas producer Williams “that will explore how highly trusted, contextualized, and auditable emissions data is transforming how companies quantify, reduce, and commercialize emissions.”
- November 2025: Context Labs began pushing more publicly for a Trace and Claim scheme. They publish a report comparing Book and Claim and Trace and Claim.
- November 2025: CATF met with the European Commission as part of the “Informal Commission expert group supporting the implementation of Regulation (EU) 2024/1787 on the reduction of methane emissions in the energy sector.”
- December 9, 2025: Context Labs joined Eurogas, the leading association representing European energy companies.
- December 10th, 2025: the EU released a memo outlining its stance on the methane regulations for discussion at December 15th meeting. That memo was not initially publicly available but Bloomberg and Reuters both receive a copy. They reported that the EU’s proposal would be drastically weakening the EU regulations. Part of that weakening would be that operators would be able to decide between submitting a trace and claim scheme or certification.
- December 12th 2025: CATF released a new report on Trace and Claim based on data put out by the University of Texas Energy Emissions Modeling and Data Lab (EEMDL). Notably EQT is a major funder of the EEMDL (and on their steering committee) and is also one of Context Lab’s biggest clients, and attended the closed door CATF meeting in May. The report claimed that Trace and Claim is the best supply chain model to reduce U.S. emissions.
- December 16th 2025: In response to reporting that the U.S. was seeking to be exempt from regulations, the New York Times released an article interviewing representatives from several major environmental NGOs. Representing CATF, Brandon Locke, the author of the original Trace and Claim report, claimed that U.S. companies have “invested billions of dollars in detecting and fixing leaks and reducing emissions.” Again, reinforcing the myth of a large supply of clean U.S. gas. with no support.
The Details
This week the EU Transport, Telecommunications and Energy Council met to discuss the implementation of the EU Methane Regulation (EUMR). After months of pressure from the oil and gas industry and Trump administration, the EU Commission succumbed, issuing a proposal that prioritizes the interests of the oil and gas industry over the environmental concerns that drove the original regulations. The proposal is vague and delegates major implementation decisions, including how the gas supply chain is tracked, to the oil and gas industry.
The EU caving to this political pressure is unfortunately not surprising, but some of the aspects of the proposal are surprising. The proposal gives two specific suggestions for tracking the gas supply chain, “certification” and “trace and claim.” To those tracking the years-long lobbying campaign that preceded the proposal, the nod to certification is unsurprising. Certification of natural gas and the nuances of who would certify it and what the criteria would be has been a central question in the oil and gas industry for years. However, the reference to trace and claim is much more surprising, especially since Clean Air Task Force (CATF), the organization that coined the term and pioneered the concept, later raised “significant doubt about whether the system can be universally implemented in the timeframe required by the regulation.” Neither suggestion actually reflects the direct climate impacts of gas imported into the EU. This work aims to explore the campaign that shaped the EU’s proposal with a particular focus on the NGOs that fought for these concepts to be included.
The EUMR, which was introduced in 2023, requires that companies importing liquid natural gas (LNG) into the EU comply with EU methane limitations and monitoring guidelines across their entire supply chain. The aspirations of the regulation were admirable, a plan that would leverage the EU’s large LNG market to drive emissions reductions in countries with weak climate commitments, like the U.S. However, the original regulation was vague regarding implementation. In particular, the regulation gave little guidance on how the EU ought to verify the claims of the oil and gas industry. Further, in the U.S., gas is typically commingled, meaning multiple companies may mix their gas together in pipelines. This practice makes the U.S. supply chain so complex that tracking a parcel of gas from a well to Europe is functionally impossible. Obviously, how these questions are resolved would have a tremendous impact on the ease with which international gas can be imported into the EU.
With so much riding on these regulations several paradigms to track the U.S. supply chain began to emerge. In February 2025, Clean Air Task Force and Rystad Energy released a report on supply chain tracking. Given the mechanical impossibility of physically tracking gas from a U.S. well to a user in Europe, the report compares the prevailing method to determine supply chain emissions, Book and Claim, against a new proposal developed by Clean Air Task Force called Trace and Claim.
Under a book and claim system, Europeans would buy gas from a supplier and then buy attribute credits (representing the monitoring and emissions standards required by the EU) from a company producing EU compliant gas. In practice, this would likely entail European importers buying gas from the Permian Basin and then purchasing credits from a lower emitting U.S. basin, likely the Appalachian Basin. The highest profile supporter of this system was MiQ, a certification company founded by RMI and the for-profit consulting company Systemiq. MiQ offers both certification of low-methane gas and a registry for companies to carry out Book and Claim transactions. CATF and Rystad’s report identified several issues with a Book and Claim system. CATF feared that under a Book and Claim system “it becomes more attractive to pay another producer across the country (or across the world) to purchase a certificate and claim the attributes of that gas.” Rather than driving emissions down, CATF noted that a Book and Claim system could incentivize operators to seek credits from existing low emission operations.
Under CATF’s Trace and Claim proposal, oil and gas companies would have to disclose their emissions every time the gas changes hands which would be recorded in a digital registry. Importers would have to demonstrate a plausible chain of custody for the gas they import to determine its emissions. Operators would still be able to sell methane credits when they produce gas significantly below the methane rules which could be purchased by other operators in the supply chain, so that they could present themselves as EU compliant. In introducing the opportunity to sell credits, CATF’s proposal arguably risked recreating the exact problem that CATF identified with Book and Claim.
Neither of these approaches reflects the reality of gas imported into Europe. Both proposals are effectively accounting practices that would allow EU importers to import gas if the gas could be EU compliant even if the gas that actually arrives in the EU is not EU compliant. Both choices are also heavily reliant on the credibility of the emissions figures presented by the oil and gas industry which is a fraught assumption. Rather than addressing these risks, CATF advocated for interoperability between existing “firms, certifiers and registries”, apparently determining that existing voluntary reporting systems were sufficiently rigorous. This assumption appears to be reflected in the EU’s proposal.
While the report was released to little fanfare, it did draw the attention of staff at the Book and Claim supporting MiQ. Axel Scheuer, an MiQ strategic advisor and former Exxon executive, harshly criticized the Trace and Claim concept. He argued that Trace and Claim would have worked in the 1970s when gas production was vertically integrated and commingling was uncommon, but that in the modern supply chain, transactions appeared far too complicated to make Trace and Claim workable. The crux of his criticism was that since most LNG suppliers are managing numerous inflow and outflow contracts simultaneously, “assigning specific outflows to particular inflows” would be “arbitrary.”
In the following months, the corporate interests aligned with CATF’s Trace and Claim system became apparent. In March 2025, a for-profit data analytics company called Context labs launched their Open Decarbonization Project (ODP). The project is an open source methodology to quantify emissions from the oil and gas supply chain using a combination of continuous monitoring, satellite data, AI and, most importantly, emissions factors set by the oil and gas clients. The press release announcing the project included a quote from CATF celebrating the project for “enabling industries to track and verify emissions more accurately.”
While the ODP is new, Context Labs has been active for over a decade. Founded in 2016 by Dan Harple, a former MIT professor, the company has provided emissions data services to many large companies including KPMG and Dell. The company’s oil and gas clients include Williams and EQT, one of the highest producing gas companies in the U.S. Context Labs’ currently sells a service to ingest environmental and operational data to create emissions estimates. Context Labs advertises that its clients use this system to automate reporting to the EPA’s GHGRP, the U.S.’s notoriously inaccurate emissions inventorying system for large facilities. Context Labs also manages a digital emissions registry called CLEAR Path which “drives trust, transparency, and visibility throughout the lifecycle of an environmental attribute.” Context Labs claims that “the platform yields the highest quality credits and certifications of low carbon intensity energy pathways available.” Notably, this registry is well aligned with what CATF’s Trace and Claim plan requires. Through CLEAR Path, Context Labs stands to profit tremendously from an EU regulatory regime that mandates or suggests a Trace and Claim system. Later statements from Context Labs makes clear that its leadership is highly aware of the opportunity CATF’s plan presents.
In May 2025, CATF hosted a closed door round table discussion on developing “credible differentiated fossil fuel markets.” The exact details of what transpired at the meeting are not known to the public. However, CATF’s press release discussing the meeting does include a guest list: “The workshop agenda included sessions led by the European Commission, the IEA, and major oil and gas stakeholders, including Williams Companies, EQT Corporation, Jonah Energy and Cheniere, non-governmental standards bodies such as the North American Energy Standards Board, as well as technology providers such as Context Labs and Attributes.” Notably, Context Labs was invited to the workshop. While listed near the end of CATF’s list of stakeholders, documents related to the meeting reveal an active role. Out of the four “major oil and gas stakeholders” that led sessions at the workshop, three were Context Labs clients: Jonah, Williams and EQT. This guest list is particularly strange because Jonah is not a major U.S. exporter. While Jonah is a large operator, there are comparatively much larger operators who were apparently excluded from the workshop’s agenda. The final stakeholder, Cheniere, is not a Context Labs client, but had been advocating for a modified form of Trace and Claim, often referred to as Trace and Aggregate, which draws on similar market principles but would anonymize the entire oil and gas supply chain up to the exporter with the onus being put on the exporter to ensure that the supply chain calculations are accurate.
Though CATF reported the roundtable as a discussion on “credible differentiated fossil fuel markets”, the workshop appears to have been a sales pitch by a for-profit company and its clients on Trace and Claim, facilitated by CATF. This assertion is also supported by Context Lab’s statement on the event: “Context Labs’ customers Williams Companies and Jonah Energy presented how they use the Context Labs platform to quantify their emissions across a highly complex supply chain.” Context Labs also stated that they pushed at the meeting for a rejection of Book and Claim systems in favor of Trace and Claim. Context Labs further positioned its services as the optimal way to carry out such a plan and claimed they would continue to lobby for its implementation: “We’ll also provide accessible overviews of the technologies we use, including blockchain, focusing on their roles in auditability, provenance, and identity assurance, with privacy and interoperability built in from the start.” This apparent emphasis on Trace and Claim to the EU decision makers is particularly concerning when it appears to have underemphasized the question of how to ensure the numbers that are protected by Context Labs’ blockchain are accurate, a particularly important question given Context Labs’ ties to the GHGRP. This concern is especially emphasized by Context Labs claiming that one of the benefits to their system is industry “privacy”.
After the meeting, CATF released a letter to the EU advocating for protecting the methane regulations. The letter includes a section on supply chain reporting. Unlike the earlier report, the letter takes a more neutral stance on Trace and Claim, identifying it as one of several solutions alongside Book and Claim & Cheniere’s Trace and Aggregate. While CATF did not comment on the relative merits of the different plans, they did link to a slide deck on Trace and Claim (it’s not clear where it was presented but given the timing it appears to be from the closed door roundtable). That slide deck strongly advocates for Trace and Claim while specifically criticizing Book and Claim. The letter does reference the closed door roundtable discussion saying that at it “major industry stakeholders and the North American Energy Standards Board illustrated how these schemes are being implemented by some companies in the US.” Given Context Labs’ statement, that is apparently a reference to Context Labs clients discussing their system. While the letter does not mention Context Labs directly, Context did amplify the letter while reinforcing the claim that Book and Claim is a worse idea than Trace and Claim.
In August 2025, CATF coauthored a publication with Environmental Defense Fund (EDF) and RMI. The report details the various proposed supply chain tracking methodologies: Book and Claim, Trace and Claim & Cheniere’s Trace and Aggregate. The report concludes that none of the plans are ideal solutions. Regarding Trace and Claim, the report states:
“Application for more complex supply chains will require cooperation between a diverse set of stakeholders across each value chain, including producers, midstream operators, gas marketers and exchanges, LNG operators and potentially regulators on issues such as contract structuring, emissions accounting and the creation and management of interoperable secure registries. The complexity of the system combined with the need for extensive cooperation in certain cases leaves significant doubt about whether the system can be universally implemented in the timeframe required by the regulation”
Given the shortcomings of each of these proposals, the report advocates for a “hybrid” approach. This hybrid proposal would require importers to do supply tracing if they are purchasing directly from the producers but if not they should work with the exporting company to create a best effort supply chain estimate for upstream and midstream. Notably, while the report also criticizes Book and Claim systems, the hybrid approach includes a reference to MiQ certification, leaving a role for RMI’s MiQ organization even if their book and claim registry is rejected.
Despite the findings of the report both CATF and Context Labs continued to advocate for Trace and Claim. In August 2025, Context Labs hosted a webinar with Microsoft and Williams Energy, two of their clients, to discuss “how highly trusted, contextualized, and auditable emissions data is transforming how companies quantify, reduce, and commercialize emissions.” The webinar was a sales pitch from Context Labs and their clients on their entire data system. The EUMR were not discussed explicitly, but Context Labs highlighted that they currently automate GHGRP reporting for some of their clients, including EQT, and anticipate being able to carry out similar automation for new regulatory regimes.
In November 2025, Context Labs published a report comparing Book and Claim and Trace and Claim. The report concludes that Book and Claim risks greenwashing while Trace and Claim has much higher fidelity. Much of the argumentation appears to be directly pulled from the CATF report on the concept, including some specific examples. While the report does not explicitly outline Context Labs anticipated role in this plan, it highlights that some operators are already carrying out Trace and Claim schemes. Both operators highlighted are Context Labs clients that use their data systems for their Trace and Claim programs and presenters to the closed door EU meeting (Williams and Jonah).
While the report is coy about Context Labs’ profit motives for supporting Trace and Claim, Eamon Monahan, Context Labs’s Director of Government Affairs, published an accompanying blog explaining Context Labs’ theorized role in this new regulatory paradigm. He argues that there are three things needed for the path forward on Trace and Claim: secure registries, robust monitoring and scalable platforms. He then concludes that “These are not theoretical. Context Labs, together with its customers and partners, is already delivering tools that make the Trace and Claim approach practical today.”
In November 2025, CATF also presented to the EU expert group on the EUMR. Again in concert with Jonah Energy, CATF advocated for a Trace and Claim system. MiQ also provided a presentation on their certification system, which is linked to a book and claim registry. The EU representatives determined that both proposals would “allow importers to provide credible evidence for compliance”, signaling the eventual EU proposal.
After nearly a year of concerted advocacy for a Trace and Claim regulatory regime, last week the EU released its implementation proposal for the EUMR. With advance access Bloomberg and Reuters reported that the EU’s proposal would be drastically weakening the EU regulations. The EU is disappointingly noncommittal about implementation stating that it will be “open to different compliance solutions”.
The proposal pulls some concepts directly from the RMI, CATF and EDF report. In particular, it draws a distinction between purchasers who are buying directly from vertically integrated producers and purchasers who are buying from an exporter that is the endpoint of a complex supply chain of producers, processors and gathers (the distinction that underpins the report’s proposed hybrid plan). For purchases without a clear supply chain to identify, the EU claims to have “identified solutions for a simple and predictable implementation.” They don’t give an exhaustive list of these “solutions” but the two that are identified specifically are Trace and Claim and Certification. No additional details are provided on how either of these would be implemented. The distinction is particularly bizarre because those two concepts are not necessarily analogues. Trace and Claim is a methodology to trace data through the supply chain. Certification is a methodology to verify emissions data, though the degree to which certification schemes are successful is questionable. Certifications have been awarded to a major donor to RMI, MiQ’s parent organization, and some of MiQ’s independent certification auditors have audited companies that they also consult for. Regardless of the credibility of MiQ’s certificates, MiQ has only made preliminary efforts to certify an entire supply chain. MiQ has proposed a Book and Claim registry to work in concert with their certification system for supply chain tracking, but that registry is not itself “a certification method”.
On December 12th, the day after the Bloomberg piece on the EU proposal was released, CATF released a new report on Trace and Claim based on data released by the University of Texas Energy Emissions Modeling and Data Lab (EEMDL). The three major funders of EEMDL, who are also members of its steering committee, are EQT, Cheniere and Williams. All three of which attended the closed door CATF meeting and two of which are also Context Labs clients. The report claims that Trace and Claim is the best supply chain model to reduce U.S. emissions. The report’s methodology is confusing, including assuming that under a Trace and Claim system, purchasers would select U.S. suppliers at random. The timing of this report’s release appears deliberately aligned with the EU Commission’s proposal.
At the core of the report and CATF’s discussion of it is an assumption that the U.S. already produces enough EU compliant gas to meet the EU’s demand. They argue that the Appalachian Basin is already producing significant compliant gas but, due to infrastructure constraints, is not able to be the sole EU LNG supplier. This claim is used by EEMDL and CATF to criticize Book and Claim systems, because they fear that the EU will import gas from dirtier U.S. basins and purchase existing Appalachian Basin attribute credits. Were this to occur, a book and claim system may not actually spur emissions reductions in the U.S. However, the assumption that there is significant clean Appalachian gas that underpins this argument is fraught. Satellite data shows that even low-emitting portions of the Appalachian basin have methane intensities of .75%, more than three times the anticipated EU intensity target. Even industry estimates for the basin’s emissions are nearly double the EU’s anticipated target. This assumption is particularly notable given EEMDL’s relationship with EQT. EQT, the largest Appalachian gas producer and major donor to EEMDL, claims to have an intensity of .007% which is well within the likely EU target. While industry and academic literature both raise questions about the availability of genuinely EU compliant gas in the Appalachian Basin, CATF and EEMDL treat this assumption as an absolute. The report provides little evidence to support it, but leverages it to criticize Book and Claim systems.
After reporting that the U.S. was lobbying to be exempt from the regulations, the New York Times released an article interviewing representatives from several of the major non-profits involved in the EU regulations, including CATF. Consistent with the CATF report based on the EEMDL data, CATF claimed that the U.S. has invested “billions of dollars in detecting and fixing leaks and reducing emissions.” Investment in reducing industry emissions has occurred, but CATF implies that these efforts have been successful, leaving U.S. companies poised to “benefit from the law”. As noted above, independent data casts doubt on the existence of the clean gas that would allow companies to benefit from the law. This claim from CATF is also a strange inversion of the argument made by the same CATF policy manager last week regarding the EEMDL report. That report’s claims centered on the assertion that Trace and Claim systems would force U.S. operators in dirtier basins to lower their emissions unlike a Book and Claim system which would allow operators to use existing investment in the Appalachian Basin to claim EU compliance. Despite advocating for Trace and Claim ostensibly because it would force new investment, CATF’s staff implied in a major publication that the U.S.’s existing investment in environmental controls had already been sufficient to profit from the regulations. The move is understandable if misguided as a tactic to soothe U.S. concerns about the regulations, but CATF’s rhetoric in a major publication like the NYT regarding existing clean gas is not supported by academic analysis on U.S. oil and gas methane emissions and reinforces the misleading claims of the oil and gas industry regarding its long term sustainability.
While Trace and Claim systems may not have drawn as much attention as certification, the EU’s support for the practice will bring it to the forefront of sustainability policy. No matter how effective a Trace and Claim procedure is to track environmental attributes, it will only be as accurate as the original data it ingests. CATF has raised some legitimate questions about Book and Claim systems, but these questions are largely moot if the core data generation problems are not addressed. Pushing forward on a dual system that allows operators multiple options to demonstrate compliance sacrifices data clarity for industry flexibility and risks the double counting of attribute credits. These problems will only be exacerbated if the underlying data is unreliable yet Trace and Claim discourse has emphasized existing “firms, certifiers and registries” and maintaining “privacy”. These priorities will limit transparency and opportunities for independent verification.
