Hydrogen use in the energy sector
Hydrogen was deemed to constitute in 2020 less than 2% of the EU total energy system, but projected to grow to circa 15% in long-term decarbonisation strategies.
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11 April 2024
Commission Delegated Regulation (EU) 2024/1041 of 28 November 2023 amending Regulation (EU) 2022/869 of the European Parliament and of the Council as regards the Union list of projects of common interest and projects of mutual interest (the 6th ‘PCI list’) published in the EU Official Journal The Regulation is highly concentrated on hydrogen infrastructure, electrolysers, interconnectors, pipelines, storages, etc. 5 April 2024
Hydrogen included (with exceptions) in Section 2 of Annex I to the Regulation (Definition of product benchmarks and system boundaries with collection of data on electricity consumption). 20 December 2023
The project to promote the production of green steel will install electrolysers nearby SHS' facilities, thereby kickstarting the development of a renewable hydrogen value chain in the Saarland region. At a later stage, SHS expects to be connected to the German hydrogen network
ACER advises future improvements in the selection process of hydrogen PCIs/PMIs
Call for evidence, REPowering the EU with Hydrogen Valleys (roadmap)
ACER has published a consultancy study on cost-benefit analysis for hydrogen networks
Council and Parliament reach provisional deal on renewable energy directive The provisional agreement provides that 42% of the hydrogen used in industry should come from renewable fuels of non-biological origin (RFNBOs) by 2030 and 60% by 2035. The agreement introduces the possibility for member states to discount the contribution of RFNBOs in industry use by 20% under two conditions: - if the member states’ national contribution to the binding overall EU target meets their expected contribution
28 March 2023 Gas package: member states set their position on future gas and hydrogen market: - General approach on the directive on common rules for the internal markets in renewable and natural gases and in hydrogen - General approach on the regulation on the internal markets for renewable and natural gases and for hydroge
15 February 2023 Commission approves €170 million Danish scheme to support renewable hydrogen production
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The European Commission hydrogen strategy of 8 July 2020 ambitions at least 40 GW of renewable hydrogen electrolysers installed by 2030 in the EU plus other 40 GW in Europe’s neighbourhood with export to the EU (ACER Market Monitoring Report 2019 – Gas Wholesale Market Volume, 23 September 2020).
The same strategy makes also the following prediction as regards the electrolysers costs:
"Costs for renewable hydrogen are going down quickly. Electrolyser costs have already been reduced by 60% in the last ten years, and are expected to halve in 2030 compared to today with economies of scale. In regions where renewable electricity is cheap, electrolysers are expected to be able to compete with fossil-based hydrogen in 2030. These elements will be key drivers of the progressive development of hydrogen across the EU economy".
Some of the EU Member States have established guarantees of origin (GOs) for renewable gases. The Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources (RED II) stipulates that the EU Member States may arrange for guarantees of origin to be issued for energy from non-renewable sources (Article 19(2) of the RED II).
 See also:
Taxonomy - manufacture of hydrogen |
According to Recital 59 of the RED II:
"Guarantees of origin which are currently in place for renewable electricity should be extended to cover renewable gas. Extending the guarantees of origin system to energy from non-renewable sources should be an option for Member States. This would provide a consistent means of proving to final customers the origin of renewable gas such as biomethane and would facilitate greater cross-border trade in such gas. It would also enable the creation of guarantees of origin for other renewable gas such as hydrogen."
However, the energy market regulators (CEER Public Consultation Paper of 22 March 2019, Regulatory Challenges for a Sustainable Gas Sector, Ref: C18-RGS-03-0, p. 19) explicitly underline “black electricity cannot be converted into green gas”. This stance is based on the RED II definition of a “renewable energy source” - decarbonised gases, e.g. hydrogen derived from natural gas through steam methane reforming or thermal methane pyrolysis, “would not be considered as renewable gas but could be included in the national GO systems as decarbonised gas, thereby making transparent to gas customers the low-carbon nature of this gas”.
The European Commission's EU Hydrogen strategy characterises low-carbon hydrogen as encompassing blue hydrogen and electricity-based hydrogen with significantly reduced full life-cycle GHG emissions compared to existing hydrogen production (European Parliament Briefing, EU hydrogen policy, Hydrogen as an energy carrier for a climate-neutral economy, February 2021, p. 3).
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ACER Market Monitoring Report 2019 – Gas Wholesale Market Volume of 23 September 2020 (p. 18 - 20) refers to the following facts on the hydrogen's use in the EU as of 2019:
- production efforts have been mainly focused on biogas, which on average accounts for 15% of EU gas domestic production and 4% of EU gas consumption,
- Germany, the UK and Italy are the frontrunners in absolute terms, while the relative weight of biogas and biomethane over final gas demand varies between the EU Member States; in Sweden, Denmark and Germany, its consumption reached 10% in 2019,
- most biogas continues to be produced and consumed close to the production site, either for heating or electricity generation,
- upgraded biomethane volumes injected into the network are still low – 5% of biogas production on average – due to higher production costs, gas quality and other technical constraints, the notable exceptions are Denmark and the Netherlands, where injections exceed 15% of biogas production,
- in absolute terms, Germany is the largest biomethane producer with more than 1 bcm in 2019,
- hydrogen is an established traded commodity in its own right, primarily produced on-site and consumed in certain industrial processes, in the refinery sector and for ammonia production – where its market value is higher than for electricity generation.,
- absolute hydrogen consumption is the highest in Germany and the Netherland,
- it is estimated that 95% of EU hydrogen production in 2018 originated from steam methane reforming (without carbon capture storage - CCS) and coal gasification, while only 5% came from electrolysis (for the latter, with a limited use of RES),
- large scale methane reforming to hydrogen with CCS is moving ahead only in the UK, a key limiting factor is the availability of suitable carbon dioxide storage structures,
- in the area of electrolysis, there are quite a few pilot and small-scale plants in operation, chiefly in Germany, France and the Netherlands.
As regards the price competitiveness of the various carbon neutral gas production technologies the said ACER Report of of 23 September 2020 acknowledges that the cost of low-carbon gases was three to more than five times higher than the price of conventional gas in 2019 - therefore, together with further technological developments and RES prices, a central element for determining the future competitiveness of all decarbonised energy technologies, including carbon-neutral gases, will be the price of carbon emissions under the EU ETS system.
Network infrastructure for the transport of pure hydrogen is not covered by Gas Directive 2009/73/EC "as the natural gas system does not include pipelines or network infrastructure dedicated to the transport of pure hydrogen" (When and How to Regulate Hydrogen Networks? “European Green Deal” Regulatory White Paper series (paper #1) relevant to the European Commission’s Hydrogen and Energy System Integration Strategies, ACER, CEER, 9 February 2021, p. 2).
Article 1(2) of the Gas Directive 2009/73/EC states in fact that the rules established by Directive for natural gas, including LNG, also apply in a non-discriminatory way to biogas and gas from biomass or other types of gas in so far as such gases can technically and safely be injected into, and transported through, the natural gas system. Therefore, while pure hydrogen transport is not subject to the Gas Directive 2009/73/EC, hydrogen production can be considered to be subject to it since a certain amount of hydrogen can be safely blended into the gas infrastructure.
Blending of hydrogen into the gas network is addressed in ACER’s 2020 Report of 10 July 2020 on NRAs Survey: Hydrogen, Biomethane, and Related Network Adaptations.
As underlined in the European Commission document of 10 February 2021 "Inception Impact Assessment, Hydrogen and Gas markets Decarbonisation Package" (Ref. Ares(2021)1159348 - 10/02/2021) "the Gas Directive and Regulation are designed for the organisation and functioning of the current fossil-based natural gas sector. They do neither anticipate the emergence of alternative methane gases, such as bio- or synthetic-methane, or other gaseous fuels, such as hydrogen, nor different production patterns. For instance, they do not integrate the distributed production of renewable and low-carbon gases and they do not prevent disruptions caused by changing gas quality. This focus on natural gas may lead to a situation in which it is more difficult to switch consumption from natural gas to renewable and low-carbon gases leading to lock-in effects or delays in a more significant deployment of renewable and low-carbon gases".
Other shortcomings of existing legal framework listed in the European Commission document of 10 February 2021 are:
- Elements of the existing gas rules, focusing on natural gas mainly imported from outside the EU, do not address the specific characteristics of decentralised renewable and low-carbon gases production within the EU. The vast majority of today’s bio-methane plants in the EU are connected at the distribution level. However, the current regulatory framework does not anticipate decentralised gas injections, meaning that the tradability and access of renewable and low carbon gases to markets and the gas grid is not on a level playing field with fossil natural gas, affecting the business case of renewable and low carbon gases producers and the costs for achieving the EU’s climate objectives. Likewise LNG terminals are not necessarily fit for receiving renewable and low-carbon gases and granting access in a transparent way.
- In comparison to the electricity sector, the gas market framework lags behind on consumer protection. The growing volumes of bio-methane and hydrogen affect gas quality (i.e. the physical characteristic of gas) and thereby the design of gas infrastructure and end-user applications and entail the risk of market fragmentation.
It is noteworthy, in the Joint letter of 29 June 2021 the major European energy market players (including ENEL, EDF, Iberdrola) called for the inclusion of the hydrogen sector in the carbon border adjustment mechanism regulation (CBAM) with the intention to avoid fossil based and highly emitting hydrogen imports, which would be similar to carbon leakage for hydrogen production.
Fit for 55 amendments - RED revision
On 14 July 2021 the European Commission presented the Renewable Energy Directive revision (European Commission Proposal for a Directive of the European Parliament and of the Council amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652, COM(2021) 557 final).
The Fit for 55 legislative Proposal introduces the definition of 'renewable fuels of non-biological origin’, which mean liquid and gaseous fuels the energy content of which is derived from renewable sources other than biomass. Moreover, the rule is established that gas and electricity from renewable sources is to be considered only once for the purposes of calculating the share of gross final consumption of energy from renewable sources. Energy produced from renewable fuels of non-biological origin shall be accounted in the sector - electricity, heating and cooling or transport - where it is consumed. The proposal includes the requirement for the EU Member States to ensure that the contribution of renewable fuels of non-biological origin used for final energy and non-energy purposes is 50 % of the hydrogen used for final energy and non-energy purposes in industry by 2030. Calculation of that percentage is to be made in accordance with the new Article 22a of the RED II.
The EU ETS proposal will include the production of hydrogen with electrolysers under the EU emissions trading system, making renewable and low-carbon facilities eligible for free allowances.
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On 31 October 2023 Directive (EU) 2023/2413 of the European Parliament and of the Council of 18 October 2023 amending Directive (EU) 2018/2001, Regulation (EU) 2018/1999 and Directive 98/70/EC as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652 (RED III) has been published in the EU Official Journal. The above legislative proposals have been included in the final text, with the reservation, that Article 22a has the following final wording:
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Article 22a Mainstreaming renewable energy in industry 1. Member States shall endeavour to increase the share of renewable sources in the amount of energy sources used for final energy and non-energy purposes in the industry sector by an indicative increase of at least 1,6 percentage points as an annual average calculated for the periods 2021 to 2025 and 2026 to 2030. Member States may count waste heat and cold towards the average annual increases referred to in the first subparagraph up to a limit of 0,4 percentage points, provided that the waste heat and cold is supplied from efficient district heating and cooling, excluding networks which supply heat to only one building or where all thermal energy is consumed only on-site and where the thermal energy is not sold. If they decide to do so, the average annual increase referred to in the first subparagraph shall increase by half of the waste heat and cold percentage points counted. Member States shall include the policies and measures planned and taken to achieve such indicative increase in their integrated national energy and climate plans submitted pursuant to Articles 3 and 14 of Regulation (EU) 2018/1999 and their integrated national energy and climate progress reports submitted pursuant to Article 17 of that Regulation. When electrification is considered to be a cost-effective option, those policies and measures shall promote the renewable-based electrification of industrial processes. Those policies and measures shall endeavour to create conducive market condition for the availability of economically viable and technically feasible renewable energy alternatives to replace fossil fuels used for industrial heating with the aim of reducing the use of fossil fuels used for heating in which the temperature is below 200 °C. When adopting those policies and measures, Member States shall take into account the energy efficiency first principle, effectiveness and international competitiveness and the need to tackle regulatory, administrative and economic barriers. Member States shall ensure that the contribution of renewable fuels of non-biological origin used for final energy and non-energy purposes shall be at least 42 % of the hydrogen used for final energy and non-energy purposes in industry by 2030, and 60 % by 2035. For the calculation of that percentage, the following rules shall apply:
For the purposes of point (c) of the fifth subparagraph of this paragraph„ in order to determine the energy content of fuels not included in Annex III, the Member States shall use the relevant European standards for the determination of the calorific values of fuels, or where no European standard has been adopted for that purpose, the relevant ISO standards. 2. Member States shall promote voluntary labelling schemes for industrial products that are claimed to be produced with renewable energy and renewable fuels of non-biological origin. Such voluntary labelling schemes shall indicate the percentage of renewable energy used or renewable fuels of non-biological origin used in the raw material acquisition and pre-processing, manufacturing and distribution stage, calculated on the basis of the methodologies laid down either in Commission Recommendation (EU) 2021/2279 (*19) or in ISO 14067:2018. 3. Member States shall report the amount of renewable fuels of non-biological origin that they expect to import and export in their integrated national energy and climate plans submitted pursuant to Articles 3 and 14 of Regulation (EU) 2018/1999 and in their integrated national energy and climate progress reports submitted pursuant to Article 17 of that Regulation. On the basis of that reporting, the Commission shall develop a Union strategy for imported and domestic hydrogen with the aim of promoting the European hydrogen market as well as domestic hydrogen production within the Union, supporting the implementation of this Directive and the achievement of the targets laid down herein, while having due regard to security of supply and the Union’s strategic autonomy in energy and level playing field on the global hydrogen market. Member States shall indicate in their integrated national energy and climate plans submitted pursuant to Articles 3 and 14 of Regulation (EU) 2018/1999 and in their integrated national energy and climate progress reports submitted pursuant to Article 17 of that Regulation how they intend to contribute to that strategy. |
New EU framework to decarbonise gas markets and promote hydrogen
On 15 December 2021 the European Commission proposed new EU framework to decarbonise gas markets and promote hydrogen, consisting of:
- Proposal for a Directive of the European Parliament Parliament and of the Council on common rules for the internal markets in renewable and natural gases and in hydrogen, COM/2021/803 final,
- Proposal for a Regulation of the European Parliament Parliament and of the Council on the internal markets for renewable and natural gases and for hydrogen (recast), COM/2021/804 final.
Before the above legislative pieces there were no rules at EU-level regulating dedicated hydrogen networks or markets. The new framework seeks to facilitate the penetration of renewable and low-carbon gases into the energy system, enabling a shift from natural gas and to allow for these new gases to play their needed role towards the goal of EU climate neutrality in 2050. The proposal observes that legal barriers exist for the development of a cost-effective, cross-border hydrogen infrastructure and competitive hydrogen market - a prerequisite for the uptake of hydrogen production and consumption.
Among deficiencies of current regulatory framework for gaseous energy carriers the above proposal identifies:
- absent rules at EU level on tariff-based investments in networks, or on the ownership and operation of dedicated hydrogen networks;
- absence of harmonised rules on (pure) hydrogen quality.
The deployment of hydrogen as an independent energy carrier via dedicated hydrogen networks should be properly promoted. Therefore, the system of terminology and certification of low carbon hydrogen and low carbon fuels is proposed.
Under the new EU Directive authorisations granted under national law for the construction and operation of existing natural gas pipelines and other network assets will be grandfathered in the administrative permit granting processes for the deployment of hydrogen production facilities and hydrogen system infrastructure (see Recital 47 of the draft Directive). Moreover, conditions for granting authorisations for hydrogen system infrastructure must not be materially different- deviations can be justified by technical safety considerations only. In turn, Annex to the draft Regulation sets important rules for the format and content of the publication of the technical information on network access by hydrogen networks operators.
Furthermore, Point 2.2.5 of the Annex I to the said Proposal for a Regulation stipulates rules for the long term use-it-or-lose-it mechanism. According to the above provision transmission system operators must to partially or fully withdraw systematically underutilised contracted capacity on an interconnection point by a network user where that user has not sold or offered under reasonable conditions its unused capacity and where other network users request firm capacity.
Contracted capacity is considered to be systematically underutilised in particular if:
(a) the network user uses less than on average 80% of its contracted capacity both from 1 April until 30 September and from 1 October until 31 March with an effective contract duration of more than one year for which no proper justification could be provided; or
(b) the network user systematically nominates close to 100% of its contracted capacity and renominates downwards with a view to circumventing the above rule.
Withdrawal shall result in the network user losing its contracted capacity partially or completely for a given period or for the remaining effective contractual term. The network user shall retain its rights and obligations under the capacity contract until the capacity is reallocated by the transmission system operator and to the extent the capacity is not reallocated by the transmission system operator.
The rule of fundamental importance is Arricle 6(6) of the said draft Regulation stating that as of 1 January 2031, hydrogen networks shall be organised as entry-exit systems.
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On 28 November 2023 Council and Parliament reached deal on the directive to establish common rules for the internal markets in renewable and natural gases and in hydrogen.
The Council and the Parliament agreed on the split between Transmission System Operators (TSOs) and Distribution System Operators (DSOs) for hydrogen.
As for the protection of vulnerable groups, member states must ensure that the right to switch supplier or market participant is granted to customers in a non-discriminatory manner in terms of cost, effort and time. The provisional agreement provides arrangements on how disconnections could take place, in order to protect customers from the future decommissioning of the gas network or its repurposing to hydrogen. Appropriate organisations need to be consulted, the customer needs to be informed in advance, and the specific needs of vulnerable customers will be taken into account.
Member states have the power to decide how to protect vulnerable customers from disconnections and to decide on how best to support them.
Finally, the provisional agreement provides for increased coordination between network development plans for hydrogen, electricity and natural gas. Network development plans will be built on sector integration, the ‘energy efficiency first’ principle and prioritising the use of hydrogen in hard-to-decarbonise sectors.
The deal on a regulation that establishes common internal market rules for renewable and natural gases and hydrogen has been reached by Council and Parliament on 8 December 2023.
The provisional agreement provides for a separate new entity in the hydrogen sector: an EU entity for Hydrogen Network Operators (ENNOH). It will be independent of the existing European Network of Transmission System Operators for Gas (ENTSOG) and the European Network of Transmission System Operators for Electricity (ENTSOE), while taking advantage of synergies and cooperation between the three sectors.
Both institutions agreed to extend the demand aggregation/joint purchasing mechanism for gas adopted during the energy crisis, though participation by gas undertakings must be fully voluntary. Gas undertakings established in Energy Community countries may participate in the mechanism as purchasers, while supplies from Russia or Belarus are excluded. In addition, the Council and the Parliament agreed on creating a voluntary mechanism for support to market development for hydrogen, with the aim to facilitate the tasks carried out by the European Commission under the European Hydrogen Bank.
The regulation will contain provisions allowing member states to adopt restrictions to the supply of natural gas, including liquefied natural gas (LNG), from Russia or Belarus, with the aim of protecting the essential security interests of the member states or of the EU, while taking account of security of supply and diversification objectives.
On solidarity, the Council and the Parliament agreed to establish default provisions to operationalise the solidarity principle in case of a crisis, where bilateral agreements are not in place. The agreement also includes the establishment of a cross-border conciliation mechanism for an ex-post revision of compensation, the voluntary reduction of non-essential consumption by protected customers, and safeguards for cross-border flows. In addition, the provisional agreement provides a voluntary mechanism, whereby on the basis of a request for solidarity by a member state, another member state not directly connected may also provide volumes of gas by applying market-based measures.
Concerning network tariffs, both institutions agreed that for the hydrogen market every national regulatory authority must consult the neighbouring national regulatory authorities on the draft tariff methodology and submit it to the Agency for the Cooperation of Energy Regulators (ACER). Each national regulatory authority will maintain the right to set its own tariff. Moreover, upon request by a national regulatory authority, ACER may propose solutions by means of a non-binding factual opinion. ACER will also inform the Commission of the outcome of such a request.
Finally, the Council and the Parliament recognised the EU's ambition to increase production of biomethane.
State aid issues
The Commission's 2022 CEEAG provide guidance on how the Commission assesses the compatibility of environmental protection, including climate protection, and energy aid measures which are subject to the notification requirement under Article 107(3)(c) TFEU. The European Hydrogen Bank is an initiative to facilitate EU-domestic production and imports of renewable hydrogen in and to Europe. Its objective is to close the investment gap and connect the future renewable hydrogen supply to consumers to meet the intended target of 20 million tonnes by 2030, contributing to the REPowerEU objectives and the transition to climate neutrality. The Innovation Fund hydrogen auctions implement the EU-domestic leg of the European Hydrogen Bank.
Under the concept of Auctions-as-a-Service, Member States may choose to use the EU-wide pilot auction mechanism under the Innovation Fund to also allocate a pre-defined amount of national funding to renewable hydrogen production projects on their territory. These projects will be assessed and ranked in the competitive auction procedure under the auction and can become eligible for national funding if the Innovation Fund budget is insufficient to cover those projects. Auctions-as-a-Service are aimed at harmonising, and tying together national and European support schemes, increasing the comparability of subsidy levels, and saving on the administrative costs to Member States and project developers of developing and understanding different hydrogen support schemes.
Examples of schemes for the promotion of renewable hydrogen
Germany
Among examples of schemes for the promotion of production renewable hydrogen it is useful to mention the German H2Global (estimated budget €900 million) approved by the European Commission on 20 December 2021. H2Global will support the production of renewable hydrogen in non-EU countries, to be imported and sold in the EU. The scheme will run for 10 years starting from the award of the first contract under the scheme. The scheme will be managed and implemented by a special-purpose entity named HINT.CO. This intermediary will conclude long-term purchase contracts on the supply side (green hydrogen production) and short-term resale contracts on the demand side (green hydrogen usage).
The aid will be awarded through competitive tenders. Prices will be determined on the buying and selling side via a double auction model, where the lowest bid price for hydrogen production and the highest selling price for hydrogen consumption will each be awarded a contract. The producers of renewable hydrogen and hydrogen derivatives such as green ammonia, green methanol, and e-Kerosene wishing to participate in the tenders will have to strictly comply with the sustainability criteria for renewable hydrogen and hydrogen derivatives production, set by the revised Renewable Energy Directive (RED II). They will also have to contribute to the deployment or financing of the additional renewable electricity needed to supply the electrolysers producing hydrogen under the scheme.
Romania
Another case is the Romanian scheme approved by the European Commission under EU State aid rules on 8 August 2022 worth €149 million made available through the Recovery and Resilience Facility to support the production of renewable hydrogen. The measure aims to contribute to the development of renewable hydrogen in line with the objectives of the EU Hydrogen Strategy and the EU Green Deal. The Romanian scheme will run until 31 December 2023 and is aimed at supporting the construction of new installations for the production of renewable hydrogen, to achieve by 31 December 2025 renewable hydrogen production capacities of at least 100 MW in electrolysis installations producing at least 10,000 tonnes of hydrogen per year. The scheme is open to (i) companies of all sizes that are active in the production of hydrogen or electricity, (ii) administrative-territorial units, or (iii) national institutes for research and development in the field of energy, including associations or partnerships formed by those actors. Under the scheme, the support will take the form of direct grants. The maximum amount of aid that can be granted per project will not exceed €50 million. The projects will be selected through a transparent and non-discriminatory bidding process, where beneficiaries will compete for the lowest amount of aid per MW of installed electrolysis capacity. The first call for projects was started in June 2022.
The 6th ‘PCI list’
On 8 April 2024 Commission Delegated Regulation (EU) 2024/1041 of 28 November 2023 amending Regulation (EU) 2022/869 of the European Parliament and of the Council as regards the Union list of projects of common interest and projects of mutual interest (the 6th ‘PCI list’) has been published in the EU Official Journal.
The Delegated Regulation, adopted under the framework of the TEN-E Regulation, is highly concentrated on hydrogen infrastructure, electrolysers, interconnectors, pipelines, storages, etc.