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As a supplementary document to Directive (EU) 2024/1788 of the European Parliament and of the Council, the core of this delegated act is to establish aGreenhouse Gas Emission Reduction Assessment System for Low-Carbon Fuels, defining emission footprint accounting standards for various hydrogen production methods and requiring a reduction of over 70% compared to fossil fuels. Its regulatory focus covers two main areas:
Clarifying Applicable Entities: It provides clear guidance for producers of blue hydrogen (natural gas-based hydrogen production with carbon capture) and specific electrolytic hydrogen (such as electrolysis powered by nuclear energy). This type of electrolytic hydrogen does not currently meet the EU's definition of "Renewable Fuels of Non-Biological Origin" (i.e., green hydrogen and its derivatives) due to the nature of its power source.
Detailed Emission Accounting: It requires hydrogen producers to incorporate default values for the carbon dioxide and methane intensity of fossil fuels (used as raw materials or process fuels), for example, the default emissions for pipeline natural gas are set at 4.9 g/MJ CO₂ and 0.19 g/MJ CH₄. The EU plans to promote the establishment of a system of default fuel emission values by country or region by the mid-2020s.
Alongside the advancement of the act, the EU is simultaneously coordinating industrial support policies and addressing industry concerns:
Hydrogen Bank Funding Coverage: The draft terms for the third European Hydrogen Bank, published by the European Commission in July, indicate that €600 million (approximately $697.5 million) will be divided into two parts, supporting both "Renewable Fuels of Non-Biological Origin" and, for the first time, includingLow-Carbon Electrolytic Hydrogen(produced from non-renewable energy sources meeting the 70% emission reduction threshold) within its support scope.
Three Key Commitments: EU Energy Commissioner Dan Jorgensen provided written guarantees, clarifying a "grandfathering clause" – projects that have made a final investment decision will not need to adapt to future revisions of the act; a commitment to uphold the principle of technology neutrality; and that a new methodology will be introduced before the end of 2026 to optimize the linkage mechanism between low-carbon electricity from nuclear power, renewable energy power purchase agreements, and hydrogen production.
The enactment of this act will fill the regulatory gap for low-carbon hydrogen in the EU, reduce industry compliance costs through unified emission accounting rules, provide clear policy expectations for technological pathways such as blue hydrogen and nuclear-powered hydrogen production, and help broaden the diversified channels for hydrogen production. With the financial support from the European Hydrogen Bank, the bill is expected to accelerate the construction of low-carbon hydrogen infrastructure and technological iteration, providing key energy support for the EU to achieve its carbon neutrality goals.
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