The EU Methane Emissions Regulation (EU-MER) sets out strong principles on penalties for non-compliance, but these must be transposed into national law by each Member State.

This paper examines the penalty provisions in the draft Romanian implementing law proposed by the Romanian government on 22 July 2025. It briefly considers the draft's legislative status, assesses its compliance with EU-MER, and compares it with good practice in Denmark and with Italy's draft law.

The paper finds that Romania, like several other Member States, is in breach of Article 33 EU-MER, having missed the 5 August 2025 deadline for adopting penalty rules. If adopt-ed in its current form, the draft would be seriously non-compliant with EU-MER requirements, in particular:

• several serious infringements are not subject to penalties;
• competent authorities are not granted the powers required by EU-MER;
• the draft does not refer to the general criteria for fines (effective, proportionate, dissuasive) set out in Art 33(2) EU-MER
• it omits the aggravating and mitigating factors listed in Art. 33(7);
• minimum fine levels are partly not dissuasive;
• the maximum fine levels are far below a level that could be considered sufficiently dissuasive.