Category: Brexit News

UK TSOs publish Cost Benefit Analysis on Loose Volume Coupling

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The Trade & Cooperation Arrangement (TCA) between the United Kingdom and the European Union sets out proposed trading arrangements to replace the UK’s membership of the Single Day Ahead Coupling (SDAC) market. Annex ENER-4 of the TCA sets out the broad requirement for this new market design, known as Loose Volume Coupling (LVC). Under LVC, the volume and flow of interconnectors between the UK and EU bidding zones directly connected to the UK are determined independently from the pan-EU SDAC market process.

As set out in the TCA, a first step in the development of the LVC solution is the delivery of a Cost Benefit Analysis (CBA). Relevant UK and EU TSOs have worked together with their consultancy partners (CEPA) to publish this first stage deliverable which can be found at the link below.

UK TSOs would like to invite wider stakeholder feedback from across the industry on the published CBA report and the supporting presentation. While the TCA sets out a formal consultation period for the development of technical procedures at a later stage, general industry feedback on the broad design of LVC as set out in the report and presentation is a key first step in the progression of the solution.

Please provide your feedback to the Nemo Link’s Customer Team or directly to any of the UK Interconnectors, ideally by 17 May 2021:

  • BritNed Development Limited
  • EirGrid Interconnector DAC
  • ElecLink Limited
  • Moyle Interconnector Limited
  • National Grid Ventures (representing IFA, IFA2 and NSL)

Industry feedback sessions are planned as follows:

  • UK – EFET-Energy UK TCA Forum (11th May)
  • UK – Joint European Stakeholder Group (11th May)
  • SEM – All Island Industry Forum (29th April)

Please contact us or any of the UK Interconnectors if you would like feedback to be shared with any other industry group not listed here.

The CBA and associated documentation is published here:

The EU TSOs will present the main findings of the CBA on the MRLVC in a workshop taking place on 4th May 2-4:30 PM CET. If you are interested in participating, please register here:

Nemo Link’s Revised Day Ahead Timings GO-LIVE 16/03/2021

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Following regulatory approval of its revised Access Rules, Nemo Link confirms that the following main changes to processes will apply from 16th March 2021:

  • The Long Term Nomination Gate Closure will be brought forward from 09:00 CE(S)T D-1 to 08:45 CE(S)T D-1
  • The Day Ahead Auction start time will be brought forward from 09:40 CE(S)T D-1 to 09:00 CE(S)T D-1
  • The Day Ahead Auction close time will be brought forward from 10:10 CE(S)T D-1 to 09:30 CE(S)T D-1
  • The Day Ahead Firmness Deadline will be brought forward from 11:00 CE(S)T D-1 to 09:00 CE(S)T D-1

These change will apply from 16th March 2021 for delivery on 17th March 2021.  Nemo Link invites interested parties to note these new timings and make adjustments to systems and processes to accommodate them.

Details of the cutover plan from the current process to the new process and further information can be found here.

As always, the Nemo Link customer team remains available to answer any questions.  Please do not hesitate to reach out to us.

Customs declarations post Brexit

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Following GB’s departure from the IEM on 1st January 2021, we wish to inform you of the changes that will take place on customs declarations when trading electricity between GB and Belgium.

Great Britain:
In the UK, Nemo Link will make import/export declarations on behalf of market participants for flows on the Nemo Link Interconnector.  There are therefore no further actions market participants need to take in the UK.

We were informed that in Belgium, network operators are not permitted to make customs declarations and therefore all market participants will need to make their own customs declarations to the Belgian authorities. According to the information provided to us, market participants that are non-EU registered can only make customs declarations through an EU customs agent or other EU-based affiliate.

We have translated from Dutch a recent communication from the Belgian customs authorities in relation to customs:


Goods imported or exported through a system of pipelines or high-voltage lines, referred to in the Code as 'fixed installations', are subject to a number of customs simplifications.
They are always considered as being under Union transit. Presentation to customs is also deemed to have been completed. In addition, they are exempt from the summary declaration, 
the temporary storage procedure and the provision of a guarantee. 
However, this does not mean that there can be an exemption from the customs declaration. 

The operators of the permanent establishments may use the legal fiction which considers that the goods have been placed under Union transit. 
A registration in NCTS is therefore not necessary. The Customs Code also exempts these movements:
- The entry summary declaration (ENS)
- Provision of a security
- Bringing under the Temporary Storage Scheme

The scheme is deemed to be terminated when an operator declares the volumes of gas or electricity through an entry in the records (see below). 
The import and export via fixed installations is in reality a continuous process. That is why it is advisable to comply with the declaration formalities by means of an entry into the declarants records (EiDR). 
After registration, the goods can be released for free circulation or exported.
In order to make the declaration process final, one global declaration of type Z must be submitted monthly or, if necessary, weekly for each operator. 
The possibility to submit these globalised declarations is part of the EiDR authorisation. 
Customs legislation does not provide for any derogations in this respect. The declaration must be made by the users of the network and not by the operators. 
A customs representative can carry out the formalities on behalf of these operators using the EiDR authorisation. 

Explanatory notes and the application forms for the EiDR authorisation can be found on the website of the customs authorities. 
Please note that although the criteria for obtaining the authorisation partly coincide with the conditions for the authorisation Authorised Economic Operator (AEO), 
holding an AEO authorisation is not necessary for obtaining EiDR.

Further information on the authorisation for Entry in the Declarant’s Records (EiDR) in Belgium can be found here.

Customs Agents and Fiscal representation

If you require a Belgian-based EU customs agent, we can recommend the following customs agents that could potentially assist you further in this matter.

We can also recommend a fiscal representative ( that works together with Remant Customs and that could act as fiscal/customs expert.

If you require any further information or assistance, as always, please do not hesitate to contact the Customer Team.

Notice to bring into effect Nemo Link’s Non-IEM Access Rules

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Ofgem and the CREG approved Nemo Link’s Non-IEM Access Rules on 18th October 2019. These Access Rules were developed for the scenario where, following its withdrawal from the European Union, the United Kingdom ceases participation in those platforms and mechanisms associated with the Internal Energy Market.

This notice, made in accordance with Article A5.1 of the approved Non-IEM Access Rules serves to bring Nemo Link’s Non-IEM Access Rules into effect for capacity delivered from 1st January 2021. Please visit our Brexit page for details on the cut-over date and further relevant information.

Nemo Link reserves the right to amend or withdraw this notice in the unlikely event the United Kingdom remains inside the Internal Energy Market. Should this occur, Nemo Link shall publish a further notice to market participants.

Please contact us on if you have any queries.


Nemo Link’s Brexit Webinar – 9th November 2020

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Nemo Link is delighted to invite interested market participants and stakeholders to our upcoming interactive webinar session on Brexit on 9th November 2020 from 14:00 to 15:30 (GMT).

This will be an opportunity for us to discuss with you our agreed trading arrangements including the day-ahead explicit auction and nomination timings when GB leaves the Internal Energy Market.

We will also walk you through our consultation about changes to non-IEM Explicit Day Ahead Auctions and welcome your feedback or questions you may have during the webinar.

Please click here to register your interest.

Details including agenda and link to the webinar will be shared to interested parties closer to the date.

If you have any questions about the event or have any specific topics you would like to include in the webinar, please don’t hesitate to contact us at

Nemo Link consults on changes to non-IEM Explicit Day Ahead Auctions

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Nemo Link already has in place a set of Non-IEM Access Rules that have been approved and will be operational from 1st January 2021 when GB leaves the IEM. This consultation proposes some minor adjustments to those trading rules, and if supported by market participants, could be implemented in Q1 2021 subject to regulatory approval.

The initial Nemo Link Non-IEM access rules were developed to enable continued trading in the event GB left the Internal Energy Market.  At the time, it was necessary to focus mainly on established operational processes to ensure a robust and smooth handover.  However, over the Brexit transition period, we have had the opportunity to assess and discuss in greater depth whether the current Non-IEM access rules can be better optimised to deliver the most efficient trading environment.

Relevant Documents
Please find below the relevant documents which outlines the proposed changes:

Consultation Invitation Letter (please read first)
Non-IEM Access Rules (track change version)

Consultation topics
The main topics of the consultation are summarised below:

  • Day Ahead Firmness Deadline changed from 11:00 to 09:00 (Appendix 1 Article 58)
  • LT Nomination window timing changed from 09:00 to 08:45 (Appendix 2 Article 6)
  • Adjustment to the timings of the explicit day ahead capacity auction that will replace the implicit day ahead auction. Nemo Link proposes moving the opening time from 09:40 to 09:00 CE(S)T (Appendix 3 Article 26)
  • Day Ahead Nomination window shortening from 12:05-14:00 to 12:05 to 13:30 (Appendix 5 Annex to the Explicit Day Ahead and Intraday Nomination Rules Paragraph 1)

In addition, Nemo Link would like to invite feedback from market participants on the following topics:

  • Do you agree a Day Ahead energy auction in GB earlier than SDAC could lead to more efficient interconnector trading?
  • How important is a single GB power reference price?

We welcome all market participant and stakeholder comments or questions on the proposals by email to by 18:00 CET 13th November 2020.

If you have any questions, please contact the Customer Team.

Brexit Update – No trading changes in the Transition Period

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Following votes both in the House of Commons and in the European Parliament ratifying the Withdrawal Agreement, the United Kingdom will leave the EU tomorrow and enter the “Transition Period”.

This means that we can confirm there will be no changes whatsoever to any trading arrangements on Nemo Link at this time and the country remains within the Internal Energy Market.  The next key date, depending on the outcome of the UK-EU negotiations will be 31st December 2020 and we will keep you notified of any developments.


It is our expectation however that the UK will not be permitted to remain within the Internal Energy Market beyond 31/12/20. Therefore Nemo Link urge all customers that have not already done so to register as physical participants to benefit from Day Ahead explicit auctions which will replace implicit auctions in the scenario that GB leaves the IEM.


Please contact the Customer Team if you would like to discuss further.

Contact Us

Please get in touch if you would like to explore trading opportunities or discuss any matters related to Nemo Link.

Customer Engagement Partner, Michele Jordan
Correspondence Address Nemo Link Limited, Rue Joseph Stevens 7, 1000 BRUSSELS, Belgium

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