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In May, the European Commission published rules on which transport fuels of non-biological origin, including hydrogen, count as renewable.
In an article for Euractiv, Guidehouse experts review the core provisions of the rules, noting their strict nature. Currently, these rules will only apply to renewable hydrogen in the transport sector but will likely be extended to other sectors—such as industry—in the future.
“Renewable electricity sourced for renewable hydrogen production must be ‘additional’ to existing renewable electricity production,” said Dr. Corinna Klessmann, director at Guidehouse. “Without this, hydrogen production could potentially increase greenhouse gas emissions because it creates additional electricity demand that might result in increased fossil power generation.”
Guidehouse experts explain that to consider electricity from directly connected installations as fully renewable, the renewable installation needs to be commissioned no earlier than three years before the electrolyzer if the electrolyzer and the renewable installation are connected through a direct line or are part of the same installation. For electricity taken from the grid to be considered fully renewable, if the electrolyzer is located in a bidding zone where the renewable electricity share exceeds 90%, the hydrogen automatically counts as fully renewable, but the maximum amount of full-load hours is capped at the same percentage.
“After a transitional period, renewable hydrogen producers will have to source and pay for renewable electricity from new and unsubsidized installations, thereby ensuring respective capacity additions,” added Dr. Klessmann.
The article was co-written by Felix von Blücher and Dr. Malte Gephart.
Guidehouse is a global consultancy providing advisory, digital, and managed services to the commercial and public sectors. Purpose-built to serve the national security, financial services, healthcare, energy, and infrastructure industries, the firm collaborates with leaders to outwit complexity and achieve transformational changes that meaningfully shape the future.