In August 2018, by an amendment to Order no. 1849/2016, the requirement was introduced for companies engaged in the wholesale or retail trade of energy products to own a warehouse to obtain an authorization. This generated many objections from energy companies. Subsequent to this, Order no. 3236/2018 replaced the old order and introduced exceptions to the requirement to own a warehouse for those that trade energy products based on fuel cards held by end-users and for affiliates of authorized warehouse keepers, registered consignees, or affiliates of companies which hold a wholesale certificate for energy products and which sell energy products only from the authorised locations of the companies with which they are affiliated.

Because the previous order was subject to a large number of legal challenges and led to numerous discussions between the authorities and the business environment about the difficulties it generated in practice, this new order removes the requirement for companies that engage in wholesale trade in energy products to own a warehouse.
The new order also removes the mention of the exemption from the requirement to own a warehouse for economic operators trading wholesale energy products based on fuel cards, but it does not clarify whether they are required to obtain an authorisation, which is needed by economic operators which intend to distribute and sale wholesale energy products.