United States natural gas markets, contracts and risks: What lessons for the European Union and Asia-Pacific natural gas markets?

The article examines the natural gas markets of the United States, the European Union and the Asia-Pacific region and their regulation and contractual structures. The article's main focus is on the United States natural gas markets. The European Union and Asia-Pacific markets are compared to this more developed market. By comparing the physical and ideological characteristics of, and differences between, the three main international gas markets, the article exposes the limits of regulatory and contractual transplants in this area of law and policy. Each of these markets is unique, which limits the opportunities for modelling certain market institutions on the basis of the more developed markets in the United States. This applies for both the EU and the Asia-Pacific region. - Highlights: • Differences in the physical markets impact regulation. • Regulatory transplants have risks. • The approach in energy policy should be based on "Law-in-Context" approach