Defining Low Carbon Hydrogen

Electrification and electrolysers deployment have been identified as critical drivers for a future decarbonised electricity system. In many cases, electrification is the most cost-efficient way to reach decarbonisation, while hydrogen Is expected to play a role in hard-to-abate sectors. Yet, not enough investments have been put on the table. One of the key reasons is the lack of clarity on how to exhaustively define hydrogen that is produced by electricity.

There Is also a remaining cost gap between renewable hydrogen and conventional hydrogen productions, together with higher technology costs and electricity costs.

It will be critical that a low-carbon hydrogen definition does not lead to two separate certification schemes for RFNBOs and low-carbon hydrogen, but that the lowcarbon hydrogen gets integrated into the RFNBO schemes under review. Asking producers to get certified twice every year would create a hustle when optimising the electrolyser's operational processes. In that perspective, the Delegated Act on Low-Carbon Hydrogen is critical to the renewable hydrogen industry. It must provide visibility on the certification of low-carbon hydrogen and ensure a level-playing field with RFNBOs. Therefore SolarPower Europe calls for a careful crafting of the Delegated Act on Low-Carbon Hydrogen, including a thorough consultation of the renewable hydrogen industry.

The ‘low-carbon hydrogen’ definition from the Gas Directive refers to ‘hydrogen the energy content of which is derived from non-renewable sources, which meets the greenhouse gas emission reduction threshold of 70% compared to the fossil fuel comparator for renewable fuels of non-biological origin set out in the methodology adopted according to Article 29a(3) to Directive (EU) 2018/2001’. This would mean that non-additional renewable electricity could not be used for the low-carbon certification. 

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