The European Commission has launched a new public consultation on the draft delegated act that clarifies the methodology for assessing emission savings for hydrogen and low-carbon fuels
On the same day, the European Commission published the new criteria for the second “Renewable H2“ auction, marking another step forward in hydrogen development. The EU executive has put a proposal for a new methodology to assess the emission savings of low-carbon hydrogen out for public consultation.
The document, on which stakeholders and citizens are invited to comment, is a draft of a delegated act. This is a secondary regulation that the Commission can adopt directly with the authorization of the Council and the EU Parliament. Specifically, this delegated act is required under the revised legislation on the EU hydrogen and gas market, which came into effect during the summer of 2024. We are referring to Directive 2024/1788/EC of June 13, 2024, which introduces several innovations in the field of H2.
Starting with the definition of low-carbon hydrogen. The text states:
“Low carbon hydrogen: hydrogen whose energy content derives from non-renewable sources and meets the greenhouse gas emission reduction threshold of 70% compared to the fossil fuel reference for renewable fuels of non-biological origin, as per the methodology for assessing greenhouse gas emission reductions achieved through renewable fuels of non-biological origin and fuels derived from recycled carbon, adopted under Article 29b, paragraph 3, of Directive (EU) 2018/2001.”
The Directive stipulates that by August 5, 2025, the EU Executive must adopt delegated acts specifying the methodology for assessing this emission reduction, ensuring that no credits are granted for avoided CO2 emissions from fossil sources whose capture has already received an emission credit.
Draft Methodology for Low-Carbon Hydrogen
The draft of the act under consultation includes, in its sole annex, the formula for calculating greenhouse gas emissions resulting from the production and use of low-carbon fuels, including hydrogen. Along with the methodology for calculating the possible CO2 capture rate and the greenhouse gas emission intensity of electricity.
Regarding the latter point, it states:
“[…] all upstream emissions arising from the cultivation, harvesting, processing, and transportation of biomass must be considered. Peat and components of fossil waste materials must be treated as fossil fuel. The fuels used for the gross production of electricity in standalone electricity plants must be determined based on electricity production and conversion efficiency to electricity.
In the case of combined heat and power (CHP) plants, the fuels used for heat produced in cogeneration must be accounted for considering alternative heat production with overall average efficiencies of 85%, while the remainder must be attributed to electricity generation.
For nuclear power plants, the conversion efficiency from nuclear heat must be assumed to be 33% or based on data provided by Eurostat or a similar accredited source.
No fuel will be associated with electricity production from renewable sources, including hydroelectric, solar, wind, and geothermal. Emissions arising from the construction, decommissioning, and waste management of electricity generation plants will not be considered. Therefore, the carbon equivalent emissions associated with the production of renewable electricity (wind, solar, hydroelectric, and geothermal) will be considered zero.”
