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Opinion on the statutory documents of the ENNOH

Opinion (C/2025/2004) on the statutory documents of the European Network of Network Operators for Hydrogen (ENNOH)

On 16 May 2025, the European Commission published its Opinion (C/2025/2004) on the statutory documents of the European Network of Network Operators for Hydrogen (ENNOH) – the independent association representing future hydrogen transmission network operators at EU level.

✅ Key Takeaways:

📌 Climate Objectives: the Articles of Association (AoA) of the ENNOH should be modified as to include climate related objectives.

📌 Membership Criteria: Only certified Hydrogen Transmission Network Operators (HTNOs) — or those undergoing certification — can be members. The “founding member” concept must align with EU law.

📌 Observer Access: Observer status should be restricted to HTNOs from countries applying EU energy law (e.g., EEA or Energy Community members).

📌 Board Composition: Rules must ensure regional balance while rewarding early movers — but with transparent limitations and future revisions.

📌 Stakeholder Engagement: Public consultations must be transparent, inclusive, and allow a default period of 2 months.

📌 Amendments & Dissolution: Changes to ENNOH’s statutory documents — including its list of members — and any dissolution must receive explicit Commission approval.

📌 Gender & Diversity: ENNOH is encouraged to integrate gender parity and diversity into board and senior role appointments.

☑️ WHAT NEXT?

The future hydrogen transmission network operators shall adopt and publish, by early July 2025, the final statutory documents, taking into account the Commission’s and ACER’s opinions.

➡️ Source: Important step towards establishing the European Network of Network Operators for Hydrogen

Posted By : admin 17 May, 2025

Enforcement of the ReFuelEU Aviation Regulation by EU Member States

How are EU Member States enforcing the ReFuelEU Aviation Regulation?

The European Commission has published an overview of the enforcement status of the ReFuelEU Aviation Regulation across EU Member States.

ℹ️ This overview was compiled based on data provided by Member States and is published for information purposes.

📅 Last updated: 5 May 2025.

Countries adopted the ReFuelEU Aviation Regulation

Countries preparing the adoption of the ReFuelEU Aviation Regulation

➡️ Source: Overview_of_Member_States_enforcement_of_RFEUA

Posted By : admin 14 May, 2025

Public Consultations. Innovation Fund

The European Commission has started the public consultation to evaluate the operations of the Innovation Fund by 2025.

📄 Form of Feedback – the online questionnaire via this link

📅 Feedback period – 15 April 2025 – 08 July 2025

✅ What is the Innovation Fund?

📌 The Innovation Fund is one of the world’s largest funding programmes for the deployment of net-zero and innovative technologies.

📌 The Innovation Fund was established by the Emissions Trading System (ETS) Directive to support innovation in low or zero-carbon products, processes and technologies in the sectors covered by the Directive.

📌 The Fund obtains its resources from ETS allowance revenues.

➡️ Source: What is the Innovation Fund?

☑️ Purpose and Scope of Evaluation:

📌 The European Commission will:

evaluate the implementation of the Innovation Fund from 2020 to 2024.
will focus primarily on assessing synergies between the Fund and other EU programmes, including Horizon Europe, and the procedures for disbursing financial support.

📌 The evaluation will assess:

Effectiveness: the degree to which the Fund has succeeded in achieving its objectives of:
1. supporting projects that demonstrate highly innovative technologies, processes and products;
2. providing financial support tailored to market needs and risk profiles of eligible projects while attracting additional public and private resources;
3. ensuring that Innovation Fund revenues are managed to accomplish the objectives of the ETS Directive.
Efficiency: how ETS allowances have been employed to achieve the expected effects of the Fund, alongside the administrative burden associated with application, evaluation, and project implementation.
Relevance: the connection between the Fund’s objectives and the attainment of EU climate targets, particularly emissions reduction and necessary technology development, while strengthening competitiveness and resilience.
Coherence: how the various elements of the Fund function cohesively to achieve its objectives and how they synergise with the EU’s policy objectives and other programmes, such as Horizon Europe, the Recovery and Resilience Fund, and InvestEU.
EU added value: the extent to which the results and impacts of the Fund contribute to changes prompted by the Commission’s intervention over what could reasonably have been expected from national actions.

➡️ Source: Industrial Decarbonisation Accelerator Act – speeding up decarbonisation

Posted By : admin 30 Apr, 2025

Lobbying activity in the EU hydrogen sector

Mapping the hydrogen power players:
Methods and Data (626 lobbying organizations analyzed), Hydrogen stakeholder population in the EU (most stakeholders are from EU, 83.22% of lobbyists represent business interests, 5.72% of lobbyists are NGOs), Bias in EU hydrogen lobbying (no inherent bias against NGO participation, clear industry bias)

Figure: Mapping the hydrogen power players

Source: Article “Mapping the hydrogen power players: An analysis of lobbying on EU hydrogen policy-making”

Article “Mapping the hydrogen power players: An analysis of lobbying on EU hydrogen policy-making” Lucas Flath, Christine Quittkat provides:

First analysis of hydrogen lobbying processes in EU policy-making.
First mapping of hydrogen lobbyists at EU-level.

✅ Some takeaways:

📌 The actual depth of the hydrogen economy will result not only from technological competition, but also from political decisions – for Europe, in particular, EU regulations and policies.

📌 It can be expected that the integration of hydrogen into the energy system will be a highly politicized process, with various actors trying to influence the transition in their own interests, as has been observed in other fields of the energy transition.

📌 European business lobbying often takes place through and by associations, which have established channels of access to political decision-makers. The European Commission, in particular, favors associations as contact partners because an aggregation of individual actors reduces the transaction costs of coordination.

📌 Corporate lobbying in the EU traditionally takes place through a multi-level chain of representation: Companies join national trade associations, which in turn are members of the corresponding associations at EU level. However in recent years, direct lobbying by individual companies at EU level has increased significantly.

📌 The membership structure of European hydrogen associations shows that hydrogen is supported by a wide range of economic sectors and actors, but in particular by mid- and downstream natural gas companies, large chemical companies, car manufacturers, and manufacturers of machinery, electronic and electrical equipment.

📌 The most well-known key factors influencing lobbying activity are material resources, such as lobbying budget or lobbying staff. Organizations with greater resources, regardless of other characteristics, are more likely to gain access to European decision makers.

📌 Characteristics of the hydrogen stakeholder population:

47.28 % – companies
35.94 % – trade associations
5.72 % – NGOs

📌 Geographical distribution of hydrogen stakeholders:

Most of the stakeholders (467; 74.60 %) are primarily organized at the national level.
139 actors (22.20 %) are primarily organized at the EU level and a small portion of 20 actors (3.20 %) represents interests organized at the international level.
Among the stakeholders organized at the national level, 410 (87.79 %) are based in EU Member States.
The most frequently represented non-EU countries are the United States, the United Kingdom, Norway and Switzerland. Germany is best represented with 166 actors (24.84 % of the total).

➡️ Source: Mapping the hydrogen power players: An analysis of lobbying on EU hydrogen policy-making. Lucas Flath, Christine Quittkat

Posted By : admin 24 Apr, 2025

Public Consultations. Delegated Act about reporting of CORSIA-eligible fuels

✈️ The European Commission conducts the Public Consultation regarding the draft of the Delegated Act about reporting of CORSIA-eligible fuels and CORSIA emissions unit cancellation reports.

📅 Feedback Period – 01 April 2025 – 29 April 2025

✅ What is the CORSIA?

The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA):

has been in operation since 2019 for monitoring, reporting and verification of carbon dioxide emissions.
is intended to be a globally applied market-based measure, which aims to offset international aviation carbon dioxide emissions from January 2021.

✅ Key Points:

📌 This Delegated Act aims to update the current rules to facilitate:

reporting of fuels eligible under the CORSIA; and
submission and verification of CORSIA emissions unit cancellation reports.

📌 ‘CORSIA eligible fuel’ means an aviation fuel certified as CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) eligible fuel by sustainability certification schemes listed in Annex I;

📌 Annex I: CORSIA approved sustainability certification schemes:

International Sustainability and Carbon Certification (ISCC)
Roundtable on Sustainable Biomaterials (RSB)
ClassNK SCS

📌 It should be possible to certify a batch of alternative aviation fuel under several schemes if it fulfils the criteria for each of those schemes. In order to prevent double claiming, aircraft operators should submit a declaration listing all GHG schemes they participate in, confirming that no amount of the alternative aviation fuel is reported more than once.

📌 This Delegated Act should apply to the emissions and use of CORSIA eligible fuels that have occurred since 1 January 2024.

➡️ Source: EU Emissions Trading System (ETS) – reporting of CORSIA-eligible fuels and CORSIA emissions unit cancellation reports

Posted By : admin 22 Apr, 2025

SAF Flexibility Mechanism

Let’s talk about the SAF Flexibility Mechanism in the EU.

✅ Main Documents:

☑️ What is the SAF Flexibility Mechanism?

📌 the SAF flexibility mechanism allows an aviation fuel supplier to supply the minimum shares of SAF as a weighted average over all the aviation fuel it supplied across all EU airports for each reporting period.

📌 the SAF flexibility mechanism is intended to give the SAF industry sufficient time to scale up its production and supply capacities.

📌 this means that aviation fuel suppliers may supply aviation fuels containing higher shares of SAF in certain EU airports to compensate for aviation fuels containing zero or lower shares of SAF in other EU airports.

📅 The SAF flexibility mechanism applies from 1 January 2025 until 31 December 2034.

✅ Some key conclusions from SAF flexibility mechanism report:

📌 Compliance with targets:

Aviation fuel suppliers can claim the supply of SAF for the purposes of complying with their ReFuelEU Aviation obligations and contributing to the national RED targets.
EU law does not prevent a batch of SAF to be certified under more than one certification scheme (e.g. RED, CORSIA certified fuels).
Aircraft operators can claim the use of a given quantity of SAF under one GHG reduction scheme, including the EU ETS and ICAO’s CORSIA.

📌 Virtual trading of SAF sustainability certificates

there is no unified industry-wide position neither on the design or the necessity of implementing such an accounting mechanism system for the purposes of complying with current blended SAF obligations and of claiming their use under other pieces of EU law, such as the EU ETS that does not allow aircraft operators to claim the use of blended SAF without physically delivery.
virtual trading of SAF sustainability certificates may bring new dynamics to the market on the demand side, but it is not clear whether this would have any real impact on the production side at this early stage.

📌 Availability of blended SAF at EU airports

the risk of a significant geographic concentration of blended SAF in few EU airports is limited.
most aviation fuel suppliers operate only within the borders of their respective Member State, so the possibility of significant geographic concentration is already largely limited to national markets.
many EU airport managing bodies have clearly communicated their intention to make blended SAF available in the coming years on their premises.
projects for new SAF capacities are appearing in various locations across the EU.

Posted By : admin 20 Apr, 2025

Public Consultations. EU ETS for maritime, aviation and stationary installations

The European Commission has commenced the public consultation regarding EU ETS for maritime, aviation and stationary installations, and market stability reserve.

📄 Type of Act – Proposal for a Directive

📅 Feedback period – 14 April 2025 – 08 July 2025

✅ The following aspects are subject to review:

📌 Aviation emissions:

the EU has temporarily limited the scope to intra-EEA flights that encourages the development of an effective global carbon pricing scheme by the ICAO.
by mid-2026, the Commission should make a report on CORSIA.
the ETS Directive suggests assessment criteria and indications on geographical scope.

📌 Maritime emissions:

the European Commission will have to assess the GHG pricing mechanism and market-based measures that will possibly be adopted at the IMO in 2025 and review the ETS accordingly to avoid a significant double burden on maritime operators;
the European Commission will have to consider extending the EU ETS to cover emissions from smaller ships (i.e. ships below 5 000 gross tonnage but not below 400 gross tonnage);
the European Commission should monitor implementation of the recent extension of the EU ETS to maritime transport, and consider legislative improvements to ensure the effective implementation of the extension;
the European Commission should simplify and improve the system where possible.

📌 Municipal waste incineration:

This looks at the feasibility of including such installations in the EU ETS from 2028.

📌 Non-permanent carbon capture and use:

the impact assessment will look at whether all GHG emissions covered by the EU ETS are effectively accounted for and whether double counting is being avoided, in particular regarding GHG emissions considered to have been captured and utilised in a product non-permanently.

📌 Carbon removals:

the possible inclusion of domestic permanent carbon removals in the EU ETS.
how the EU ETS could account for negative emissions resulting from GHGs that are removed from the atmosphere and safely and permanently stored underground or permanently stored in products;
how those negative emissions, if appropriate, could be covered by ‘emissions trading’ or other policies, setting a clear scope and strict criteria;
putting in place of safeguards to ensure that such removals do not offset necessary emissions reductions.

☑️ WHAT NEXT?

📌 At the end of this consultation process, a factual summary report and a synopsis report will be drafted.

📌 The Commission Adoption – Q3 2026.

➡️ Source: EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve – review

Posted By : admin 10 Apr, 2025

Hydrogen in Coalition Agreement

On 9 April 2025, the German political parties published their coalition agreement.

✅ Parties of the agreement:

CDU/CSU – the Christian Democratic Union of Germany / Christian Social Union
SPD – the Social Democratic Party of Germany.

☑️ What is a Coalition Agreement:

is an agreement between the parties that form a coalition government.
identifies the most important shared goals and objectives of a new government.
is legally not binding for Parliament.

➡️ The Coalition Agreement is available via this link

✅ Hydrogen in the Coalition Agreement:

📌 Hydrogen economy:

climate-friendly hydrogen from various sources.
the long-term goal is to transition to climate-neutral hydrogen from domestic production and imports.

📌 Reduction of Overregulation:

to advocate for pragmatic national and European regulations and their rapid implementation.
overregulation must be reduced.

📌 Hydrogen Production:

through large, system-supporting electrolysis plants; and
increasingly in a decentralized and nationwide manner.

📌 Hydrogen Import:

to consistently expand energy partnerships and the cross-border and necessary domestic infrastructure for imports of hydrogen and its derivatives in all directions.
this includes connections to all German and European ports.

📌 Hydrogen Funding:

to utilize national and European funding instruments, such as H2 Global, IPCEI projects, and specific programs for SMEs.

📌 Hydrogen Infrastructure:

the hydrogen core network must connect industrial centers throughout Germany, including in southern and eastern Germany.
hydrogen storage facilities must also be taken into account.
the financing conditions must ensure that the core network is implemented and the distribution network is also developed in an integrated plan.

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