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European institutional debate on requirements for renewable hydrogen production.

Updated: Feb 7

Date of publication: 02/07/2023

The production of renewable hydrogen has opened in recent years a very complex European debate on its promotion. First of all, the requirements of additionality, temporal correlation and geographical correlation are important for the theme. Understanding such elements helps to understand un what conditions it is possible to produce renewable hydrogen. So, the topic generates repercussions on the implementation of the hydrogen measures of the national PNRR.

Moreover, there are differences between the "green hydrogen", the "renewable hydrogen" and the "sustainable hydrogen". In fact these expressions are not interchangeable.

renewable hydrogen

Renewable hydrogen

Renewable hydrogen belongs to the macro-category of liquid or gaseous fuels used in transport. This differs from biofuels or biogas, whose energy content comes from renewable sources other than biomass.

“Sustainable” or “green” hydrogen

Green hydrogen is the clean variant of hydrogen. In particular, it isn’t present in nature and it is produced through renewable sources, following the electrolysis process. After this process its subsequent transformation produces energy and water vapor, without generating polluting effects. So, green hydrogen as clean energy can be stored and used in various sectors. For example, it is used in transport, industrial heat production, up to the introduction into the gas transmission.

European regulations and directives

According to Regulation 2021/2139, hydrogen production activity contributes substantially to climate change mitigation. This is possible if it meets the greenhouse gas emission reduction requirement for certain percentages of the regulation. What’s more, renewable energies in the European energy mix aim to reduce greenhouse gas emissions. This is done to meet the commitments made by the Union in the Paris Agreement.

Furthermore, the introduction of art. 194 TFEU represents an important stage in the transfer to the Union of specific powers in the field of energy. It also formalizes the close link between environmental and energy policy. Now, as for the requirements of the fifth and sixth subparagraphs, they refer to the characteristics of electricity from renewable sources. In particular, they refer to energy used to produce renewable liquid and gaseous fuels of non-biological origin for transport.

According an European Directive the Commission should develop a reliable Union methodology. This methodology should ensure a correlation between the electricity production unit and fuel production. In addition, the fuel producer should contribute to the deployment of renewable energy or its funding.

renewable energy

Objective of European directives

First objective of the European directives is to contribute to the reduction of greenhouse gasses. To talk about this goal is possible to isolate the following conditions for the production of renewable hydrogen:

  1. electricity used for its production must be of renewable origin;

  2. correlation between the production of electricity from renewable sources and the consumption of electricity by the electrolyser;

  3. technical clarification for the understanding and evaluation of the operation of electrolysers.

Therefore, they are important elements because they are electrochemical devices that allow water molecules to break. In particular, it is the process of electrolysis that separates hydrogen from oxygen.

Options of supply of electrolyzers

The electrolysers can be powered by ad hoc renewable plants and it is not necessary to take energy from the network. Therefore, the problems of additionality and correlation in the production phase do not arise. Alternatively, the electricity that allows their operation is taken from the electricity grid. As a result, it is necessary to conclude an agreement to purchase electricity generated from renewable sources. This is called a “power purchase agreement”.

renewable energy


The European Parliament sent a clear message to the Commission to simplify and make the rules for the production of hydrogen. In fact the European institutions are at an impasse. This is why the Commission has developed a tendency to revise and update the regulatory framework. So, the trend is relevant for the ecological and energy transition to accelerate it.

New reviews are on trans-European energy infrastructure, trans-European transport networks, energy taxation, and others. These new revisions are aimed at ensuring adaptation to the technological innovations applicable to the energy sector. However, they are dictated by the need to ensure adaptation to technological innovations applicable to the energy sector. Another reason is the need to ensure compliance with increasingly ambitious standards for the promotion of renewable energy sources.

Last but not least, interinstitutional negotiations have recently been opened on the adoption of the delegated regulation. So, a political compromise should be reached as soon as possible to accelerate the transition to a hydrogen economy.


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