Eurogas’ recommendations on the low-carbon fuels delegated regulation

In this paper, Eurogas provides an assessment of the low-carbon fuels delegated regulation, highlighting elements that it welcomes, providing recommendations on what should be improved, identifying challenges, and adding requests for clarifications.

Download the full Eurogas assessment and recommendations in the PDF below.

Eurogas welcomes the intention of the European Commission to define the necessary elements for the certification of low-carbon fuels (Art. 9 of the Hydrogen and Gas Directive) in order to support a clear regulatory framework, a prerequisite for their needed ramp-up.

We believe that low-carbon hydrogen will represent an important part of the EU hydrogen mix and will have a crucial role in the development of the hydrogen market and infrastructure, providing the volumes necessary to materialize the overall and renewable hydrogen ambitions of Europe as stated in the REPowerEU.

Low carbon hydrogen and its derivatives can deliver GHG savings, and as for all renewable and low carbon energy, these GHG credentials should be the main benchmark when determining their value in a net zero future.

As noted in the Gas Package, imports of renewable and low-carbon hydrogen are likely to complement domestic production, and certain sectors are already foreseeing consumption of low-carbon hydrogen and its derivatives. Indeed, low-carbon hydrogen also opens the way for low-carbon derivatives, such as low-carbon methanol and low-carbon ammonia, both representing important pieces in the decarbonisation of hard-to-abate sectors, such as maritime and aviation transport, chemical and power generation. Contrary to RFNBOs, low-carbon fuels have only been indirectly incentivized in EU legislation, notably through policies at consumption level (e,g. FuelEU Maritime).

Against this background, Eurogas express concerns on several aspects of the Delegated Regulation, which would endanger the deployment of low carbon hydrogen and represent a hinderance for the realisation of the EU hydrogen ambitions as a whole. Additionally, these aspects could represent an obstacle in scaling up EU's hydrogen market and in strengthening European industry competitiveness vis-a-vis third countries.