France Hydrogène reacts to the two delegated acts adopted by the European Commission for renewable hydrogen

The framework finally adopted lays a major stone for the recognition of French energy choices.

The delegated act in article 27(3) of directive 2018/2001 (known as RED2), which defines the rules for the production of renewable hydrogen, has indeed been enriched with a new method relative to the previous versions presented by the Commission to the Member States.

For any electricity mix with a carbon content of less than 18gCO2eq/MJ (defined at bidding zone level), electrolyzers connected to the electricity network may count up to 100% of their production as RFNBOs provided that they are supplied in quantities renewable energy equivalents via Power Purchase Agreements (PPAs).

The electrolyser must be located in the same bidding zone as the renewable energy assets to which it is connected via PPAs (geographical correlation), and operate at times when electricity is produced by these renewable energy assets. This temporal correlation can be monthly until December 31, 2029, but will switch to hourly steps from January 1, 2030.

Thus, in France and Sweden, the renewable energy assets to which the electrolyzers are connected via PPAs will not necessarily have to be additional (i.e. put into service no later than 36 months before the in service of the electrolyzers), nor to respect the criterion of absence of State aid.

This has major positive impacts, making a considerable volume of renewable energy installations eligible for hydrogen production in France. And this allows French electrolysers in particular to obtain supplies, in particular from hydroelectric power stations. It will therefore be possible to produce only RFNBOs out while maintaining a high load factor, a decisive point for the competitiveness of the hydrogen produced and to meet the need for stability in the hydrogen supply of end users (particularly industrial).

Although this is a considerable advance, it would be wrong to consider it as an acknowledgment of the role of nuclear hydrogen, or low-carbon electrolytic. The European Commission is only responding here to a fundamental right of the Union, that of the free choice by the Member States of their energy mix: given the fact that France already relies on a low-carbon electricity mix, conditioning the deployment of the Hydrogen to the construction of new assets for the production of renewable electricity would automatically lead to excess capacity and would therefore disregard the said principle.

But, as it stands, the hydrogen produced by electrolyzers connected to the French electricity network which would be supplied by nuclear power capacities (via a long-term contract for example) instead of renewable PPAs, could not be counted in the reaching the targets for the use of renewable hydrogen defined in RED3, nor entering the scope of the Innovation Fund or the announced scope of the European Hydrogen Bank.

For Philippe Boucly, President of France Hydrogène: “The adoption of the two RFNBOs delegated acts is a crucial step for the European and national sector to make the final investment decisions, and for Europe to retain its industrial leadership in hydrogen. These rules appear today as a fair compromise between a strict methodology, aimed at ensuring that the development of hydrogen leads to major reductions in greenhouse gas emissions, and the temporary relaxations necessary for the massive launch. of any industrial sector. We welcome the establishment by the European Commission of specific rules for States that already have a carbon-free electricity mix, such as France. Although the adoption of this provision constitutes an important step forward, it nevertheless remains only the minimal expression of France's legitimate right to base its decarbonization on a mix of renewables and nuclear. And cannot therefore assume any withdrawal of our claims to be able to count low-carbon electrolytic hydrogen, produced from nuclear, for the achievement of European targets for the use of decarbonated hydrogen, as well as its inclusion in the panel of European support systems set up (Innovation Fund, H2 Bank, etc.). The story does not end there, we will continue our efforts to ensure that hydrogen produced from nuclear electricity is recognized in achieving decarbonization targets. »