After giving a concise overview of the penalty provisions in the EU Methane Regulation (EU-MER), this paper counters the scaremongering narrative promoted by fossil energy groups that the EU-MER creates "unmanageable liability" for EU fossil-fuel importers through fines of up to 20% of annual turnover. In fact, the maximum penalty can be imposed only in cases of intentional, exceptionally serious, repeated and unremedied breaches, combined with a blatant lack of cooperation with public authorities. Companies can readily manage this risk by making genuine efforts to comply.

The paper also compares the penalty rules in adopted or draft implementing acts in Czechia, Denmark, Hungary, Italy and Romania, identifying best practice in Denmark's law, largely good practice (with some important exceptions) in Italy's draft, but serious compliance gaps in the (draft) laws of Czechia, Hungary and Romania.

Finally, it warns of the risk of "enforcement shopping", especially regarding importers' compliance, and highlights areas where the European Commission could issue informal guidance to support consistent enforcement of penalty regimes.