Zeebrugge: The terminal on this stretch of Flemish coast has spent four years as the most politically awkward piece of infrastructure in Europe, and it has around a hundred days left in that role. Under the regulation phasing out Russian gas, given its final green light by the Council on 26 January 2026, deliveries of Russian liquefied natural gas under long-term contracts become unlawful on 1 January 2027. Short-term and spot purchases have already been prohibited since 25 April 2026, and Russian pipeline gas under short-term arrangements since 17 June.
What happened in the interval is being read as a scandal, and it is better understood as arithmetic. In the first half of 2026 the Yamal project shipped 140 cargoes carrying some 10.25 million tonnes, of which more than 97 per cent went to European ports, at a value of roughly six billion euro. Record volumes ahead of a dated prohibition are exactly what a dated prohibition produces. Buyers holding take-or-pay obligations lift everything the contract permits while lifting remains legal, because the alternative is paying for gas they never receive. The behaviour was predictable from the moment the phase-out was given a calendar rather than a trigger.
The legal architecture around exit has also moved. The Union’s sanctions work gave European buyers force majeure cover to leave Russian contracts early, and the twentieth package adopted in April extended protection against financial claims to TotalEnergies, which holds a fifth of the Yamal project and lifts roughly five million tonnes a year under arrangements running to 2041. Germany’s state-owned SEFE sits on a further 2.9 million tonnes annually. The contracts were always the hard part, and the Union chose to indemnify its way out rather than litigate its way out.
The strategic question is what the ban actually does to Russian revenue, and the honest answer is less than the headline suggests. Cargoes blocked from Europe do not evaporate; they sail further, to Asian buyers, at longer voyage distances and therefore at worse economics for the seller. How much worse depends on ice-class shipping availability, on transhipment options now closed in European waters, and on whether Asian demand absorbs the volumes at prices that make Arctic production worth continuing. The regulation’s effect runs through logistics and freight, not through the legal text, and the Commission’s own estimate of roughly 33 billion cubic metres removed annually between 2025 and 2028 is a statement about flows, not about the seller’s balance sheet.
Europe’s own replacement problem is more manageable now than it would have been three years ago. A substantial wave of new liquefaction capacity from the United States and Qatar is arriving across 2026 and 2027, which is precisely why the phase-out was dated where it was. The trade is a price risk that has largely passed for a concentration risk that has not. Replacing Russian molecules with American ones leaves Europe more exposed to a single supplier whose export policy is set in a political system Europe does not influence, and that exposure is not priced in any of the impact assessments.
Then there is enforcement, which is a customs problem wearing an energy policy costume. Once origin becomes the operative legal fact, someone must verify it at the terminal gate for cargoes that may have been blended, re-sold, transhipped outside Union waters or documented through intermediaries. The regulation obliges importers to demonstrate origin, but demonstrating origin for a fungible commodity is a discipline European customs authorities have built for timber and steel and are only now building for gas.
Two dates remain open after New Year’s Day. Pipeline gas under long-term contracts stops on 30 September 2027, or 1 November if storage targets for the coming winter are missed, which converts a filling season into a legal deadline. And arbitration over cancelled contracts will run for years regardless of the indemnities, in tribunals that answer to contract law rather than to Brussels. The ban takes effect in a hundred days. The consequences will take considerably longer.
