EU says “renewable hydrogen” valid only for electrolysers linked to new wind and solar

The European Union has finally published its official legal definition of renewable hydrogen, requiring electrolysers to be connected to new renewable electricity production.

Published on Monday, the European Commission proposed two detailed rules defining what constitutes renewable hydrogen in the EU.  At the heart of the proposed rules is the requirement that all renewable fuels of non-biological origin (also known as RFNBOs) are produced from renewable electricity.

While seemingly obvious, the specifics are what are really important, particularly that of “additionality”.

Basically, the proposed rules lay out that electrolysers be connected to new renewable electricity production – ie, renewable energy production which began operations not more than three years earlier.

This concept of additionality is designed to ensure that green hydrogen production does not cannibalise existing renewable energy generation, and instead operates under newly installed capacity.

Many had called for a strict interpretation of additionality that would have started from 1 January 2027, but the proposed ruling has set the additionality clause to apply from the start of 2028 instead.

This allows for existing commitments and development to continue development, but ensures stricter guidelines are imposed as the need for renewable energy and green hydrogen increase.

Thus, for electrolysers that are directly connected to a renewable energy source and not linked to the power grid, the additionality clause is the only condition that must be met before it can be classified as renewable hydrogen.

For electrolysers connected to the grid, developers and operators will need to produce their own renewable power or sign Power Purchase Agreements (PPAs) for renewable electricity.

However, the restrictions on how closely the time of hydrogen output must match renewable energy production have been relaxed compared to previous drafts of the rules, with a monthly correlation required through to the end of 2029, before switching to an hourly correlation from the start of 2030.

Previous versions of the draft had required monthly correlation only applying until the end of 2026 and hourly correlation being implemented by 2027.

“Renewable hydrogen is a crucial component of our strategy for a cost-effective clean energy transition and to get rid of Russian fossil fuels in some industrial processes,” said Kadri Simson, the EU commissioner for energy.

“Clear rules and a reliable certification system are key for this emerging market to develop and establish itself in Europe. These delegated acts provide much-needed legal certainty to investors and will further boost the EU’s industrial leadership in this green sector.”

Finally, there’s been some confusion over whether the Commission’s new Delegated Act allows green hydrogen to be produced using nuclear power. Major news groups like Bloomberg and Reuters have reported this to be the case, but an analysis here argues these reports are based on a misunderstanding.

“The confusion seems to have arisen from a new clause in the document – one that had not been seen in previous draft versions – which will allows France to avoid the need for ‘additionality’ in green hydrogen production in future years due to its low-carbon nuclear-dominated electricity grid,” says Leigh Thomas.

This means that while France could qualify to get around the additionality clause for its grid-connected green hydrogen projects – if its existing nuclear fleet is all up and running ok – it can not produce renewable hydrogen from new nuclear power.