France Hydrogène’s position on the rules governing the production of renewable hydrogen (RED III)
The European Union has spent months drawing up the rules and conditions which will govern the production of renewable hydrogen. The European Commission’s delay in publishing the delegated acts provided for under articles 27 (3) and 28 (5) of the Renewable Energy Directive (RED II), and the European Parliament’s vote on 14th September on the revision of the directive (RED III), have created uncertainty and regulatory flux which are harmful to the entire European hydrogen sector.
With the opening of formal trilogue meetings between the European Parliament, the Council of the European Union and the European Commission, France Hydrogène has identified seven proposals which it believes could help resolve the debate over striking the right balance in terms of the regulations that should govern the production of renewable hydrogen:
- Regulatory certainty as soon as possible: Regulatory flux places Europe’s leadership in this field at jeopardy.
- Retain the additionality principle, with specific exemptions that should be granted to projects which were operationnal before 2030.
- Exemptions for all zero carbon electricity sources: the bonus to countries where renewable energy accounted for over 90% of electricity consumed must also benefit to countries where the electricity generation is more than 90% fossil fuel-free thanks to a combination of renewables and nuclear power.
- Abolish the criteria banning financial aid for renewable energy installations.
- An appropriate temporal correlation between the hydrogen production unit (electrolyzer) and the installation or installations generating renewable electricity destined for this unit and governed by a PPA. The Commission’s proposal provided for a requirement for renewable hydrogen and the renewable electricity used to produce this hydrogen to be produced during the same calendar month until 2030, after this, it must be produced within the same calendar hour, a position which seems like a reasonable compromise between facilitating the launch of new hydrogen production projects and continuing to set the bar high in relation to decarbonization goals.
- The same rules for both domestic hydrogen production and hydrogen imports: without this, rules and regulation would give rise to competitive distortion and open the door to greenwashing in third countries.
- Recognition of the role of low-carbon hydrogen, especially that produced using nuclear power, to be enshrined in EU legislation, by opening the door to low-carbon hydrogen to fulfill the RFNBOs targets set within RED III.
Download the position paper in PDF format below :