European policymakers urged to adopt robust low-carbon hydrogen definition

Industry players, non-governmental organizations (NGOs), and think tanks have issued a joint letter calling on European policymakers to adopt a robust definition for low-carbon hydrogen after thorough consultation of stakeholders.

In the joint letter released on April 2, the signatories, including Renewable Hydrogen Coalition, Transport & Environment, and Danish Shipping among others, urge the European Commission (EC) Executive Vice-President Maroš Šefčovič and Energy Commissioner Kadri Simson to adopt a robust definition for low-carbon hydrogen in the upcoming delegated act (DA) pursuant to article 8 of the Hydrogen and Decarbonised Gas Market Directive.

The signatories expressed their concern over calls for the adoption of a “quick” low-carbon hydrogen definition, which would “fall short of being fit for purpose and aligning with the mandate given by the Hydrogen and Gas Decarbonisation Directive”.

“Article 8 of the Gas Directive lists several complex issues that will require novel regulation and cannot be done quickly. A robust definition is crucial to provide market players with investment certainty, ensure a true level playing field with renewable hydrogen, and guarantee that low-carbon hydrogen contributes effectively to climate mitigation efforts, rather than hampering them,” the letter states.

In December 2023, the European Parliament and Council agreed on clear building blocks to define low-carbon hydrogen.

The joint letter said that these should now be substantiated in the upcoming delegated act with concrete, measurable proposals, and proposes the following elements to be included:

• Definition of the main hydrogen production pathways, including hydrogen made with electricity from the grid, nuclear power, fossil fuels, but also hydrogen derived from renewable electricity that is only partially compliant with the RFNBOs DA.
• Full lifecycle climate warming emissions assessment based on real-world data to measure the footprint of low-carbon hydrogen and deliver genuine emissions reduction of at least 70% compared to the fossil fuel comparator established in the Gas Directive.
• Minimum carbon capture and storage (CCS) rate based on actual CO2 captured and sequestrated as well as a maximum methane leakage rate.
• Accurate and transparent emissions monitoring and verification system by an independent third-party.

Additional safeguards were also proposed:

• Introduce a clause ensuring that low-carbon hydrogen made from fossil fuels is only made from existing (non-additional) gas production capacity.
• Prohibit carbon offsetting to demonstrate compliance with the low-carbon hydrogen DA and current emissions reduction threshold of at least 70%, or any future threshold.