Energy Regulation Solutions

Maryna Hritsyshyna

Energy Regulation Solutions

Maryna Hritsyshyna

  • Energy Regulation Solutions

    Maryna Hritsyshyna

    About us

    Energy Regulation Solutions offers specialized regulatory consulting at the intersection of innovation, climate goals, and market readiness. We support developers, investors, and policymakers in navigating complex regulatory landscapes for hydrogen, CO₂, and Power-to-X technologies in the EU, Germany, and the US

Category Archives: Regulation news

Author Image Posted By : admin 6 Jul, 2025

Amendments to the EU Climate Law

Amendment to the EU Climate Law by the European Commission

On 2 July 2025, the European Commission proposed an amendment to the EU Climate Law, introducing a 2040 climate target:

✅ 90% reduction in net GHG emissions by 2040, compared to 1990 levels.

📄 Proposal for a 2040 EU climate target is available via this link.

☑️ Main Proposals:

To support the achievement of the 2040 EU climate target, the European Commission will ensure that future legislative proposals appropriately reflect a broad set of guiding principles and priorities, including:

📌 Starting from 2036, high-quality international credits (up to 3% of 1990 emissions) under Article 6 of the Paris Agreement, supporting both EU and global efforts to stay below a 1.5°C temperature rise.

📌 The role of domestic permanent removals within the EU ETS to address residual emissions in hard-to-abate sectors.

📌 Enhanced flexibility across sectors for cost-effective progress.

📌 Use of the best available science, including IPCC and Advisory Board reports.

📌 Consideration of social, economic, and environmental impacts, the costs of inaction, and the benefits of action over the medium and long term.

📌 Ensuring a just and socially fair transition for all.

📌 Promoting technology neutrality, simplification, economic efficiency, and security.

📌 Positioning climate action as a driver for investment and innovation.

📌 Strengthening the global competitiveness of EU industries, especially SMEs and sectors most exposed to carbon leakage.

📌 Supporting affordable and secure energy, efficiency, and the energy efficiency first principle.

📌 Maintaining and enhancing natural carbon sinks and protecting biodiversity.

📌 Addressing investment needs and financing opportunities.

📌 Aligning with international efforts under the Paris Agreement and the UNFCCC.

✅ Next Steps:

The proposal will be submitted to the European Parliament and the Council for discussion and adoption under the ordinary legislative procedure.

➡️ Source: EU’s Climate Law presents a new way to get to 2040

Author Image Posted By : admin 27 Jun, 2025

EEA report

Renewables, electrification and flexibility — for a competitive EU energy system transformation by 2030

Renewables, electrification and flexibility - For a competitive EU energy system transformation by 2030

The EEA report ‘Renewables, electrification and flexibility — for a competitive EU energy system transformation by 2030’.

✅ Key Insights:

📌 The EU has made remarkable progress in cutting electricity-sector CO2 emissions over recent decades. However, decarbonising heating and transport — still dominated by gas and oil — lags behind.

📌 Scaling up domestic renewable electricity generation, together with improvements in energy and resource efficiency, can replace volatile fossil fuel imports with cleaner, lower-cost energy.

📌 If 2030 renewables and efficiency targets are met, variable electricity generation costs in the EU could fall by up to 57% compared to 2023 levels. In the long term, this means lower consumer prices, though near-term investments in grid flexibility and infrastructure will be essential.

📌 The shift to green hydrogen as an industrial feedstock will significantly increase electricity demand post-2030. By 2050, hydrogen use could rise more than tenfold compared to the end of this decade, with around 65% dedicated to industrial applications.

📌Meeting climate goals requires a rapid decline in fossil fuel use: annual oil reduction must double by 2030, while gas use must fall eightfold. This would cut the fossil energy share from 59% in 2022 to 6% by 2050.

📌 Urgent priorities include:

  • Unlocking capital to expand renewable capacity to 77% of total installed capacity by 2030.
  • Doubling system flexibility through smart grids, storage, and demand response.
  • Strengthening EU-wide coordination to balance regional disparities and improve resilience.

➡️ Source: Renewables, electrification and flexibility – For a competitive EU energy system transformation by 2030

Author Image Posted By : admin 27 Jun, 2025

Clean Industrial Solutions and Aid Framework (CISAF)

📢 On 25 June 2025, the European Commission adopted the Clean Industrial Solutions and Aid Framework (CISAF) — a major step to align State aid rules with the goals of the Clean Industrial Deal.

This new framework provides targeted support for low-carbon fuels, including low-carbon hydrogen, RFNBOs, and synthetic fuels, through structured investment aid schemes.

🔹 What’s new for hydrogen and e-fuels?

The European Commission will consider compatible with the internal market aid measures to support:

  • investments for the production of low-carbon fuels
  • investments for the production of RFNBOs
  • investments in storage for low-carbon fuels that store exclusively low-carbon fuels, or a mix of low-carbon fuels and RFNBOs.

🔹 Key conditions:

  • 30% of budgets must be reserved for RFNBOs
  • GHG reduction threshold of 70% for low-carbon fuels
  • Aid applies only to new capacity
  • Schemes must remain open, non-discriminatory, and compliant with the ‘Do No Significant Harm’ principle.

✅ This is a promising signal for project developers and industrial actors across Europe. The CISAF framework may play a critical role in de-risking early investments in the hydrogen economy and scaling up low-carbon fuel production.

➡️ Source: Clean Industrial Deal State Aid Framework (CISAF)

Author Image Posted By : admin 25 Jun, 2025

Regulatory Update: Low-Carbon Hydrogen Rules

In Search of the Real Price of Blue Hydrogen

Source: In Search of the Real Price of Blue Hydrogen

📢 Regulatory Update: Low-Carbon Hydrogen Rules

The European Commission plans to finalize the Delegated Act for low carbon hydrogen in the coming months, with implementation planned before the end of the year.

At the same time, growing concerns remain about the viability blue hydrogen. This is confirmed in the recent report by the Green Hydrogen Organization: “In Search of the Real Price of Blue Hydrogen”, available via this link.

✅ Key Takeaways from the report:

📌 Low-carbon hydrogen – not proven at scale

  • No current projects meet the emissions criteria of the EU, US, UK, Japan, or Korea.
  • True low-carbon production would require 95%+ carbon capture and permanent, verifiable CO₂ storage

📌 Carbon capture performance is inconsistent

  • Among 16 reviewed CCS projects, none have consistently captured more than 80% of CO₂ emissions.

📌 High uncertainty = risky pricing assumptions

  • Unlike green hydrogen projects, carbon capture assumptions are not validated by real-world performance.
  • Volatile gas prices and gaps in life-cycle emissions reporting make pricing blue hydrogen highly speculative.

☑️ CONCLUSION: clarity, predictability, and consistency in definitions and requirements will be essential to build trust and attract investment in low-carbon hydrogen pathways.

➡️ Source: Commission’s draft rules make low-carbon hydrogen ‘practically impossible’, say stakeholders

Author Image Posted By : admin 22 Jun, 2025

Renewable Energy Directive (RED III) implementation in Germany

RED III implementation in Germany

The German Federal Ministry for the Environment has submitted a draft bill for the further development of the GHG reduction quota for consultation with associations. The law serves to implement the requirements of the amended Renewable Energy Directive (RED III).

✅ The main changes:

📌 General overview:

  • The mandatory percentage reduction in GHG emissions for fuels will be set until 2040 and will gradually increase to 53%.
  • The GHG reduction quota must be met by all fuel suppliers for all transport sectors.
  • The separate quota for RFNBO in aviation will be replaced by a general quota for all transport sectors.
  • The quota for advanced biofuels will be increased and the double counting will be abolished.
  • Renewable fuels can only be counted if on-site inspections by government inspectors are possible.

💧 The minimum shares of RFNBO for the transport sector is:

  • 0.1 % from 2026,
  • 0.5 % from 2028,
  • 1.5 % from 2030,
  • 2 % from 2032,
  • 3 % from 2034,
  • 5 % from 2035,
  • 7 % from 2037,
  • 9 % from 2039,
  • 12 % from 2040.

📊 For the calculation of the reference value against which the GHG reduction must be achieved, the energetic quantity of the RFNBO multiplied by a factor of:

  • 3 from the commitment year 2024,
  • 2.5 from the commitment year 2035,
  • 2 from the commitment year 2036,
  • 1.5 from the commitment year 2037,
  • 1 from the 2038 commitment year.

The factors shall additionally be multiplied by 1.5 if the respective fuel is used in aircraft or vessels.

✈️ Aviation:

  • Previous PtL Quotas for aircrafts (in paragraph 4a § 37a) are excluded;
  • New PtL Quotas are defined under the ReFuelEU Aviation Regulation;
  • An aviation fuel supplier is defined as anyone who, on a commercial basis or within the framework of commercial enterprises pursuant to the Energy Tax Act, places on the market aviation turbine fuel under subheading 2710 19 21 of the Combined Nomenclature.
  • Penalties for non-compliance with PtL Quotas by aviation fuel suppliers:
    • for SAF – EUR 4,700 per tonne;
    • for e-SAF – EUR 17,000 per tonne.

➡️ Source: Referentenentwurf eines zweiten Gesetzes zur Weiterentwicklung der Treibhausgasminderungs-Quote

Author Image Posted By : admin 21 Jun, 2025

The Impact of Renewable Hydrogen on the Power System

electrolyser at the intersection of the hydrogen and electricity markets, the associated revenue streams, and possible support mechanisms

Figure: Electrolyser at the intersection of the hydrogen and electricity markets, the associated revenue streams, and possible support mechanisms

Source: Market Design and Regulatory Framework for Viable and Flexible Hydrogen Production Report, June 2025

New ENTSO-E Report: The Impact of Renewable Hydrogen on the Power System

This comprehensive report offers valuable insights into the growing hydrogen market and its interdependence with the electricity system.

✅ Key Takeaways:

📌 System Integration is Key

Electrolysers and hydrogen facilities should be strategically planned, located, and operated in coordination with the power system to maximise system benefits and consumer value.

📌 Location Matters

Whether near renewable energy sources, hydrogen demand centers, or both — the siting and grid connection (on-grid/off-grid) of electrolysers are crucial for infrastructure optimisation, especially as natural gas is phased out.

📌 Smart Regulation & Market Design

Policies defining renewable hydrogen must consider not just the hydrogen sector, but also incentivise investments that support the power system and accelerate decarbonisation.

📌 Flexibility Potential

Electrolysers could provide valuable short-duration flexibility via implicit and explicit demand response, especially as the market matures.

📌 Contributing to Resource Adequacy

Power-to-Hydrogen (P2H2) supports the grid through demand response. Hydrogen-to-Power (H2P) can offer carbon-neutral backup via repurposed gas turbines and capacity mechanisms.

📌 Certification Trade-offs

Hydrogen regulation (e.g., GOs and RFNBO criteria) must find a balance between strict decarbonisation goals and power system needs. To strike a balance, GOs and RFNBO requirements should be designed with flexibility in mind.

➡️ Source: Report on Impact of Renewable Hydrogen on the Power System

Author Image Posted By : admin 12 Jun, 2025

Hydrogen in the Reformed EU ETS

green and blue hydrogen costs

Figure: Comparing green (left) and blue hydrogen (right) costs accounting for EU ETS impacts (assumed CO2 price: 80 €/tCO2) based on the optimistic end of near-term cost estimates for 2025 to 2030. The value of free allocations is calculated based on CBAM factor of 100 %, which applies until the end of 2025. No additional subsidies considered here.

Source: Nils Bruch, Falko Ueckerdt, Michèle Knodt (2025): Hydrogen in the Reformed EU ETS – Implications for Competitiveness and Emissions Reductions. Kopernikus-Projekt Ariadne, Potsdam.

Hydrogen in the Reformed EU ETS: What It Means for Competitiveness and Emissions Reductions?

🔹 Key insights:

📌 The EU ETS alone cannot make hydrogen competitive.

  • Hydrogen production (both renewable and blue) remains significantly more expensive than natural gas — currently 4 to 6 times more costly.
  • The value of freely allocated ETS allowances does little to close this gap, as illustrated in the picture below with the green part, especially with today’s relatively low CO₂ prices.

📌 To bridge the cost gap and enable a fuel switch from natural gas to low-carbon or renewable hydrogen, CO₂ prices of €300–500/tCO₂ would be necessary.

📌 Switching from blue to green hydrogen would require €2500/tCO₂ if only downstream emissions are priced.

✅ Policy recommendations include:

📌 Expanding the EU ETS to cover upstream emissions for a more accurate climate cost signal.

📌 Gradually lowering the emission intensity threshold (currently 28.2 gCO₂eq/MJ) for low-carbon hydrogen to encourage innovation and deeper decarbonisation.

💡 To use hydrogen for the energy transition, it is essential to go beyond emissions pricing and rethink how to support its competitiveness and climate impact.

Author Image Posted By : admin 6 Jun, 2025

IEA World Energy Investment 2025 Report

investment in selected low-emissions fuels in selected regions, 2023, 2024 and 2025

Figure: Investment in selected low-emissions fuels in selected regions, 2023, 2024 and 2025

Source: World Energy Investment 2025 report, 10th Edition

Investment in liquid biofuels, biogases and hydrogen is set to rise by 30 % in 2025, to nearly $25 billion, building on a 20 % rise in 2024.

📌 Low-emissions fuel spending varies greatly by region:

  • in 2024, Europe accounted for 60% of global investment in biogases;
  • the US made up 70% of global investment in biojet kerosene;
  • China has large investments in hydrogen;
  • Brazil focuses on liquid biofuels.

📌 Investment in liquid biofuels, biogases and low-emissions hydrogen is set to rise by 30% in 2025 to a record high close to USD 25 billion, building on a 20% rise in 2024.

📌 Policies and regulations remain essential to this growth: mandates, quotas and other forms of policy support have underpinned the high levels of investment in biodiesel and ethanol in the United States and Brazil and in biogases in Europe.

📌 Some hydrogen projects have been cancelled or delayed in the past 12 months, but there remains a pipeline of projects that have received FID, requiring around USD 8 billion of investment in 2025, a 70% increase from the level in 2024.

📌 For hydrogen:

  • there were a number of setbacks for projects around the world, nonetheless, investment rose by 60% in 2024, and there remains a large pipeline of hydrogen production projects that have received FID.
  • government support has continued in 2025 globally, for example, in Australia and the EU.
  • all hydrogen projects that have received FID would require investment almost USD 8 billion and would increase capacity to around 7.5 Mt in 2035.

➡️ Source: World Energy Investment 2025 report, 10th Edition

Author Image Posted By : admin 4 Jun, 2025

Regulatory work in PtX projects

regulatory frameworks across countries

Source: Sustainability regulations for PtX projects

Why does regulatory work matter in PtX projects?

Because the success of PtX projects doesn’t just depend on technology — it also depends on navigating a complex and often fragmented regulatory landscape.

The table above highlights how diverse and misaligned regulatory frameworks are across countries.

This complexity becomes even more critical for import-oriented PtX projects, where compliance is needed with both the exporting and importing country’s rules.

✅ Key challenges:

📌 Diverging national regulations

📌 Different GHG emission thresholds

📌 Contradictions between high renewable potential and low renewables deployment in some exporting countries.

These factors can hinder project bankability, delay timelines, or even block market access.

That’s why aligning regulatory frameworks — or at least understanding and navigating their discrepancies — is crucial for enabling global hydrogen and e-fuel markets.

➡️ Source:

Stefan Bube, Katja Lange, Dayana Granford Ruiz, Sebastian Schindler, Marie Plaisir, Martin Kaltschmitt, Jochen Bard, Klemens Ilse.
Sustainability regulations for PtX projects: Scope and impact analysis,
Joule,
Volume 9, Issue 6,
2025,
101966,
ISSN 2542-4351,
https://doi.org/10.1016/j.joule.2025.101966.

Author Image Posted By : admin 2 Jun, 2025

Mapping the cost competitiveness of African green hydrogen imports to Europe

Overview of African green hydrogen projects by country and end use

Figure: Overview of African green hydrogen projects by country and end use

Source: Mapping the cost competitiveness of African green hydrogen imports to Europe

📃 Article “Mapping the cost competitiveness of African green hydrogen imports to Europe” was published by researchers of the Technical University of Munich (TUM), the University of Oxford and ETH Zurich.

✅ The Key Findings:

📌The research covers:

  • all projects planned to be operational by 2030.
  • the analysis of African countries with port access.
  • 31 countries, except Somalia and Libya, were excluded due to political instability and small island states.

📌 Overview of African green hydrogen projects:

  • 34 projects are found across 7 countries;
  • 89% of projects are either at concept or feasibility stages;
  • 2 of the projects have reached a financial investment decision and are under construction, and only one small-scale project (that is, 3.5 MW) in South Africa is operational;
  • From 3.5 MW to 6.9 GW is planned project sizes;
  • 74% of planned electrolyser capacity is intended for ammonia (NH3) production

📌 Levelized cost of hydrogen (LCOH):

  • In a high interest scenarios 1 and 2, least costs for green H2 exported from Africa are €4.9 kgH2−1 without policy support and €3.8 kgH2−1 when fully de-risked by European governments.
  • In a low interest scenarios, the costs come down to €4.2 kgH2−1 and €3.2 kgH2−1, respectively.
  • no location competitive with the first round of auction results by the European Hydrogen Bank, which yielded a lowest bid of €2.8 kgH2−1 in Spain.

📌 Challenges:

  • many low-cost locations are in regions that are either politically contested or encounter relatively regular flares of armed conflict.
  • the size of the planned investments relative to the GDP raises questions on feasibility. This situation is concerning as many African countries face massive foreign debt burdens.
  • whereas wind resources are critical to low-cost green H2 production, local expertise to install this wind capacity may be insufficient.
  • some low-cost locations, such as those near the Red Sea or the river Nile in Egypt, may also face challenges of water insecurity potentially disrupting consistent production.

➡️ Source: Egli, F., Schneider, F., Leonard, A. et al. Mapping the cost competitiveness of African green hydrogen imports to Europe. Nat Energy (2025).