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"How Does the EU Define Renewable Hydrogen and What Makes Hydrogenerous Carbon Positive?"


Hydrogen by new definitions:


  • 1.Renewable hydrogen (sometimes referred to as clean hydrogen)

  • 2.Low-carbon hydrogen

  • 3.Fossil-based hydrogen (without CCS)

Hydrogen by color:

  1. Green hydrogen (renewable electricity through electrolysis)

  2. Blue hydrogen (natural gas with CCS)

  3. Grey hydrogen (natural gas), brown hydrogen (brown coal), black (black coal)

  4. Electricity from Grid. (Electrolyses)


> The European Commission-delegated Regulations defining the legal framework for renewable hydrogen as an alternative energy source have entered into force

> These Acts, which entered into force on 10 July 2023, are part of the EU legal framework for renewable hydrogen, which is still rudimentary at present, but defines the requirements for including combustibles and fuels in the targets of the member states in the field of renewable energy

> The enactment of these regulations comes after the European Commission presented two Delegated Acts {DAs) to implement the requirements of Art. 27 (3) and Art. 25 (2), 28 (5) of the Renewable Energy Directive 2018/2001 (RED II)

> The first DA defines the requirements for the production of hydrogen, and fuels based on these, so they can be counted as Renewable Fuels of Non-Biological Origin {RFNBOs) within the meaning of Art. 2 no. 36, 25 (2) RED II towards the minimum share of renewable energies in the transport sector. Therefore, in addition to hydrogen, the definition also refers, in particular, to derivatives such as ammonia, methanol, paraffin and other hydrogen-based e-fuels

> Although Art. 27 (3) RED II refers exclusively to the transport sector, the definition has significance far beyond this, as the Commission has proposed in the context of RED Ill that RFNBOs can count towards the renewable energy targets regardless of the sector in which they are consumed. In other words, the first DA determines what is to be understood by green hydrogen and its derivatives for the whole of EU law and is, therefore, of central importance for ramping-up the hydrogen economy

> The requirements apply both to production in the EU and to third countries, which explains the global interest in the Commission's proposals. In order to prove the sustainability criteria, a system of voluntary certification has been proposed in accordance with Art. 9 of the first DA. The Member States are to be required to recognize the certificates if the Commission has approved the certification scheme in question in accordance with Art. 30 (4) RED II

> The second DA based on Art. 25 (2) and 28 {5) RED II contains the methodology for calculating greenhouse gas emissions and, therefore, implements the target set out in Art. 25 (2) RED II of greenhouse gas savings for RFNBOs of at least 70% from 1 January 2021 compared to the fuels to be replaced

> The fossil benchmark for RFNBOs is set at 94g CO2-eq/MJ (Annex A.2.). Taking into account the savings target of at least 70% of grey hydrogen production, this results in emissions of maximum 28.2g CO2-eq/MJ for RFNBOs. For hydrogen, this means a limit value of 3.38t CO2-eq/tH2. Hydrogen and hydrogen-based fuels that exceed this value are not automatically excluded as renewable fuels, but they cannot be counted towards the Member States' renewable energy targets.


An important consideration in the production of RFNBOs from renewable hydrogen is the classification of the CO2 used in the process. The Annex to the second DA regulates the conditions under which captured CO2 can be considered as an avoided greenhouse gas emission, i.e. its use in the production of RFNBOs is possible. The following case groups are envisaged:


CO2 from industrial processes that are covered by an emissions trading scheme. However, this option is only available for CO2 from electricity production until 2036, in all other cases until 2041.


CO2 that is captured from air.


CO2 from the production or combustion of biofuels or biomass that meet the sustainability criteria and that have not received greenhouse gas emission saving credits.


CO2 from the combustion of RFNBOs that meet the criteria of the second DA.


We call Hydrogenerous new technology Green-Green Hydrogen, hope you understand why?







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