The level of permissible greenhouse gas emissions for green hydrogen production and distribution in the European Commission’s new Delegated Act has been criticised as “too high” and “insufficient” by experts.
Documents unveiled on Monday allow 3.38kg of CO2-equivalent (CO2e) for every kilogram of renewable hydrogen produced and distributed to end users in a “full lifecycle” approach.
But this emissions standard — defined as a 70% reduction from a fossil-fuel “comparator” of 94gCO2e/MJ — has been slammed by the Green Hydrogen Organisation (GH2) trade body and research house BloombergNEF (BNEF).
“3.4kgCO2e/kgH2 is too high even using the European Commission’s full lifecycle approach including upstream emissions, emissions associated with taking electricity from the grid, from processing, and those associated with transporting these fuels to the end-consumer,” GH2 CEO Jonas Moberg tells Hydrogen Insight.
“The world needs at least 100 million tonnes of green hydrogen by 2030. At 3.4kg/kgH2 this would amount to 340 million tonnes of CO2e entering the atmosphere which we simply can’t afford.”
And in a note to subscribers, BNEF described the emissions threshold as “insufficient”.
“The threshold may appear more lenient than other government standards, but it covers a greater emissions scope,” the analyst explained.
“However, it won’t incentivise the production of net-zero H2.”
Moberg points out that the EU signed up to the hydrogen Breakthrough Agenda at COP26 in Glasgow in late 2021 — which made a recommendation in a 2022 report that hydrogen “production routes will need to achieve verifiable low-carbon intensities that trend towards near zero by 2030”.
Geneva-based GH2 last year launched its own Green Hydrogen Standard for renewable H2 production of 1kg of CO2e per kg of H2 — not including distribution to end users, unlike the EU standard — which it is pushing industrial players to voluntarily sign up for.
“The Green Hydrogen Standard places an upper limit of 1kgCO2e/kgH2 calculated up until the point of production and we have committed to lowering this value over time in line with the COP26 Glasgow Breakthrough Agenda’s recommendation.”
How does the EU standard compare to others?
The UK has set a definition of “low-carbon” hydrogen of 20g of CO2e per MJ, which translates to 2.4kg of CO2e per kilogram of H2, which covers total emissions from the production of both green and blue hydrogen.
However, as this does not cover the distribution of the H2 to the end user, it is difficult to compare it directly with the EU standard.
In the US, the Infrastructure Investment and Jobs Act of November 2021 defined “clean hydrogen” as “hydrogen produced with a carbon intensity equal to or less than 2 kilograms of carbon dioxide-equivalent at the site of production per kilogram of hydrogen produced”.
This was subsequently extended in a draft guidance document about the Clean Hydrogen Production Standard (CHPS) in September 2022 to 4kgCO2e/kgH2 when including lifecycle greenhouse gas emissions, such as upstream methane emissions — but not distribution to end users.
The Inflation Reduction Act, which became law in August 2022, also offers tax credits for hydrogen produced with lifecycle emissions of less than 4kgCO2e/kgH2 — but this is on a sliding scale. So only hydrogen manufactured with less than 0.45kgCO2e/kgH2 would receive 100% of the $3/kgH2 credit, followed by 33.4% for 0.45-1.5kgCO2e/kgH2, 25% for 1.5-2.5kg and 20% for 2.5-4kg.
The US CHPS is not expected to be finalised, however, until later this year.