Consultation Response – 08/06 EU Hydrogen Strategy

The EU Hydrogen strategy will explore how clean hydrogen can help reduce the EU economy’s carbon emissions in a cost-effective way. It is in line with the EU’s goal – set out in the European Green Deal – to be climate-neutral by 2050. It should also help the EU recover from COVID-19’s economic impact.

In our consultation response Bellona Europa suggests that  setting thresholds and climate criteria for hydrogen production will be crucial to stimulate the development of truly low-carbon fuels. When produced in accordance with robust environmental standards, different hydrogen sources can aid co-developing transport infrastructure, supplying the same market and growing the share of hydrogen as a clean energy source.

95% of hydrogen used today is produced from fossil fuels, predominantly via fossil methane steam reforming (SMR). With the CO2 coming from the process vented into the atmosphere, the production of fossil hydrogen contributes to an overall increase of emissions and is not compatible with European climate goals.

We therefore recommend:

  • When calculating the emissions of hydrogen from electrolysis, the following emissions should be taken into account.
  • Using breakeven points to define truly low-carbon hydrogen could be a way to strengthen current prerequisites for the production of these fuels in the EU Hydrogen Strategy:
  • To ensure the compatibility with climate goals declining thresholds for carbon intensity (e.g. 100gCO2eq/kWh to 0gCO2eq/kWh by 2050 from the Sustainable Finance Taxonomy) should be used for financial mechanisms supporting low-carbon fuels.
  • Predictions of the emission factor of the grid in 2030 and 2050 should not be used to calculate the climate impact of electrolytic hydrogen today.

In terms of infrastructure development, Bellona Europa highlights that:

  • Dedicated infrastructure for handling and transport of low-carbon fuels (e.g. hydrogen and ammonia) to avoid blending within the large natural gas grid.
  • Investment in hydrogen projects meeting the thresholds for low climate impacts in comparison to their fossil counterparts (e.g. in a region with electricity emission factor of 50gCO2/kWh)

Find the full consultation response here: