Ref. Ares(2020)5233700 - 05/10/2020
Hydrogen Europe input to the EC Communication on “Building a hydrogen economy for a
climate-neutral Europe. A strategic roadmap.
In view of the upcoming Communication on a Hydrogen Strategy, we welcome the opportunity to provide our input at
this stage of the drafting process. In this document, we take the opportunity to focus on two topics. In particular, the
topic of definitions
which is crucial. The other topic concerns the transportation of hydrogen via pipeline
inefficiency; on this we would like to provide clarity. We thank you for your consideration and remain at your full
Defining concrete definitions to recognise hydrogen produced via differing production methods is a prerequisite for
kick-starting a hydrogen economy. Rapid agreement on a comprehensive and science-based uniform EU-wide
terminology is necessary
to adapt legal definitions and provide a clear taxonomy which brings with it legal certainty.
To ensure both legal and investor certainty, the definition for “renewable hydrogen” needs to be aligned with the
definitions outlined in article 2.1 of the renewable energy directive specific to “energy from renewable sources”
the main body of the draft communication, the current definition stipulates that renewable hydrogen is hydrogen
produced by water electrolysis, whereby the electricity stems from renewable electricity. However, renewable
hydrogen can also be produced from e.g. biogas, biomass or biogenic/organic waste (as reflected in the annex of the
draft communication). It is the resource that determines whether or not it is renewable, not the technology.
With regards to the definition for “low-carbon hydrogen
”, electricity based hydrogen is highly dependent on the carbon
intensity of the electricity used to produce it (e.g. 0,7 / 0,9 kg CO2/kg H2 in Sweden and Lithuania to over 40 kg CO2/kg
H2 in Estonia and Poland). We believe low carbon hydrogen should be defined as hydrogen produced from feedstock
of non-renewable origin, with a greenhouse gas intensity of no more than a certain threshold
. At present, there are
different threshold values appearing across different pieces of EU legislation and/or noteworthy certification schemes,
Sustainable Finance: Taxonomy regulation → stipulates 48.3 gCO2eq/MJ which corresponds to using electricity
below or equal to 100g/kWh;
Renewable Energy Directive → GHG methodology proposed foresees that hydrogen for the transport sector
would have to be produced at or below 28,231 gCO2eq /MJ;
CertfiHy → threshold is 36.42 gCO2eq/MJ.
A clear definition, with a clear threshold is essential. As such, the hydrogen strategy should stipulate the importance of
a singular overarching approach. Α fixed benchmark related to carbon content is needed
that on the one hand enables
the production of low carbon hydrogen but on the other hand does not discourage the rapid uptake of renewable
hydrogen at a competitive price before 2030.
On the basis of the above-mentioned adjustments, the definition of “clean hydrogen” would also need to be adjusted to recognise both renewable hydrogen and low carbon hydrogen as clean forms of hydrogen
. Today, over 90% of the
hydrogen produced in the European Union comes from unabated fossil fuels. One of the priorities of this strategy should
1 70% of the average GHG values of gasoline and diesel under the RED II (94 g CO2/MJ)
2 60% of SMR
be the promotion of renewable and low-carbon pathways that wean the Union
away from unabated fossil-based
production means. Scenarios that rely on only one production pathway seem unrealistic and would fall short of the
required deployment at rapid scale. Also, we must always have in mind the ultimate objective which is to reach climate
neutrality in 2050.
Concluding, the adoption of a methodology for the calculation of the life cycle greenhouse gas emissions from
renewable and low carbon hydrogen is needed
and should also be reflected in the EU-wide terminology to allow
comparability between energy sources
in terms of the emissions factor. CO2 content of energy carriers and vectors
will become the new currency of the energy system and the EU economic recovery
. As such, we encourage the
European Commission to take into account the work undertaken as part of the CertifHy project, which can serve as a
good starting point for the development of this methodology, but additionally to take into account the role of ‘negative
emissions’.3 Furthermore, a transparent mechanism for tracking and tracing the carbon content is required
would enable a clear taxonomy and prioritisation. Hydrogen transportation via pipeline
The draft Communication refers to hydrogen transport becoming inefficient
at distances around 1,500km compared
to natural gas at 3,500km. In a study
undertaken for the US Department of Energy, it is clearly highlighted that at the
same flow speed the pressure drop for hydrogen is lower than for natural gas and therefore the
pump/compressor load for hydrogen is lower than for natural gas
. There are no losses related to the
value/volume of the molecules transported.
Furthermore, transportation of H2 via pipeline is a more cost effective and efficient way of transporting large volumes
of renewable energy
as compared to transport via the electricity grid. This can be illustrated by the following
comparison of the gas and electricity interconnectors between the United Kingdom and the Netherlands4.
3 It has been indicated that the CertifHy project is willing to adapt according to the evolution of EU rules and definitions.
4 Vermeulen U, Turning a hydrogen economy into reality, presentation at 28th meeting Steering committee IPHE, the Hague, 2017
Regarding the storyline developed for the realisation of hydrogen infrastructure, the draft communication suggests that
connecting infrastructure internationally will take place post 2030. However, in order to connect the optimal resource
production sites in Europe (offshore wind in the North and solar and wind in the South) to demand centres, one
needs to consider international connections earlier.
This becomes even more important when the storyline extends
to imports of hydrogen from our neighbours e.g. North Africa and Ukraine.