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
On 23 September, I had the pleasure of speaking at the German-African Green Hydrogen Forum at Hochschule Anhalt, University of Applied Sciences. It was inspiring to exchange ideas on the main challenges of hydrogen imports with delegates from different countries and leading experts in the hydrogen sector.
This weekend I dove into the report “Assistance in the development of an auction design and necessary pre-conditions for a European import auction for renewable hydrogen under the European Hydrogen Bank.”
The EHB is based on domestic and international pillars. While the domestic pillar for hydrogen production in the EU has already reached its third auction, the international pillar for hydrogen import is still under development. This report provides the groundwork for shaping a European import auction for renewable hydrogen and its derivatives.
My Key Takeaways:
1️⃣ Strategic recommendations:
The report outlines how to design RFNBO import auctions at EU level, based on hydrogen market analysis and lessons from existing/planned auction schemes in Europe and beyond.
2️⃣ Two case studies analyzed:
📌 Pipeline-based imports (pure hydrogen):
Can secure supply/offtake contracts between EU buyers and third-country producers in neighbouring regions.
Encourages pipeline investments.
Works via demand-side auction models to bridge funding gaps for RFNBO purchases, without assuming counterparty risks.
Helps EU offtakers secure RFNBO volumes for hard-to-abate sectors and quota compliance.
Contributes to scaling up the global RFNBO market.
3️⃣ Contract terms
To scale import volumes effectively, the maturity transformation between purchase and sales agreements should be limited, with hydrogen sales agreements (HSAs) running for 2–5 years.
4️⃣ Auction design priorities
Import auctions should:
Bridge the cost gap between RFNBO production abroad and EU willingness to pay.
Accelerate market ramp-up.
Send a strong demand signal to international producers.
Strengthen cooperation among EU Member States.
💡 This report is an important step toward designing the EU’s approach for international hydrogen imports as a key enabler for the energy transition.
In this episode of Clean Energy Talks video blog with Roxana Serpa, Vice President of H2 Peru Association, we talk about hydrogen import from Peru to the EU:
I. Introduction of H2 Peru Association
The work of H2 Peru and its main activities in the hydrogen sector.
II. Renewable Energy Potential in Peru
What is the estimated renewable energy potential in Peru that could be used for green hydrogen production?
III. Regulatory framework
What recent developments in Peru’s regulatory framework could support the export of hydrogen to the EU?
IV. Transporting Hydrogen to Europe
What are the most viable options for transporting hydrogen from Peru to the EU?
Green ammonia
Sustainable aviation fuels (SAF)
Renewable methanol (for maritime transport).
V. Hydrogen Production Outlook
What opportunities exist for launching hydrogen production projects in Peru in the near to mid-term?
VI. Hydrogen Hubs
What is meant by a hydrogen hub, and what plans or locations are being considered for such hubs in Peru?
VII. Certification
How is Peru preparing to meet the certification requirements for hydrogen exports to the EU?
➡️ Reach out here on LinkedIn or contact me for more details on the video topic.
This report, prepared at the request of the European Parliament’s Committee on Industry, Research and Energy (ITRE) reviews the draft Delegated Act (DA) on low-carbon fuels and addresses following questions:
🔹 Which production pathways are included?
The DA applies a technology-neutral, life-cycle approach.
Fuels must achieve at least a 70% reduction vs. the fossil comparator (94 gCO₂eq/MJ).
Both fossil pathways with CCS and electrolytic production routes for hydrogen production are eligible.
Nuclear-based electricity is also recognised.
Hydrogen leakage will be included once scientific consensus exists on its warming impact.
🔹 Does the DA enable the hydrogen economy?
The Delegated Act (DA) is a regulatory enabler, not a market driver.
The DA creates regulatory certainty via harmonised EU-wide accounting and certification, reducing investment risk and avoiding fragmented national rules.
The DA is not a demand-side driver, no targets or incentives are included.
🔹 Does the DA address fossil fuel emissions?
The DA incorporates methane CH₄ and CO₂ defaults but they are not strongly conservative.
LNG-specific values are missing, risking underestimation. Its effectiveness will hinge on strict enforcement and robust methane reporting.
🔹 Price & cost expectations
Blue H₂: 3.5–6.5 €/kg (costs depend on gas prices, CCS costs, and volatility).
Electrolytic H₂: 6–8 €/kg today; costs could fall <3 €/kg with cheaper electrolysers + low-carbon electricity.
➡️ Overall: The DA is an important regulatory enabler. It sets the rules for certification and trade but does not itself stimulate hydrogen demand.
Figure: Global clean hydrogen projects by project status
Source: Hydrogen Council & McKinsey Project & Investment Tracker, as of December 2020, May 2022, May 2024 and July 2025
The global hydrogen sector is evolving, and this image from the Global Hydrogen Compass 2025, published by Hydrogen Council, illustrates the current landscape.
✅ Key Takeaways:
📌 The clean hydrogen project pipeline now includes 1,749 projects, of which 510 are committed —meaning they have taken FID, started construction, or begun operation. Over 80 projects were added in the past year.
📌 The overall hydrogen project pipeline has grown 7.5 times since 2020, with 214 net new projects added since May 2024, despite a slowdown in announcements.
📌 Europe leads in the number of projects with commercial operation dates (CODs) by 2030, followed by North America and China.
📌 Around 70% of committed projects are renewable, with just under half located in Europe.
📌 While Europe focuses on developing infrastructure and demand centers for an import-oriented hydrogen industry, China’s renewable projects are on average 10 times larger.
📌 A higher share of Chinese projects (50%) are already FID+ compared to Europe (30%) and North America (35%). Early-stage projects in China may be undercounted due to lower public visibility.
The new report “Synergies of green hydrogen and biobased value chains deployment. Report WP2: Case studies on hydrogen produced from biomass” was released by the Inter-Task Project Synergies of Green Hydrogen and Biobased Value Chains.
The report explores technology options for producing biomass-based hydrogen (biohydrogen) and their respective technology readiness levels.
✅ Regulatory context
It is important to underline that biohydrogen does not qualify as renewable hydrogen or renewable fuel of non-biological origin (RFNBO) under the Renewable Energy Directive (RED III), since biomass is explicitly excluded from the definition of RFNBO.
RED III: ‘renewable fuels of non-biological origin’ means liquid and gaseous fuels the energy content of which is derived from renewable sources other than biomass;
Nevertheless, the report provides valuable insights into how different biomass conversion technologies could contribute to hydrogen and commodity production.
Figure: Main conversion processes to produce hydrogen from biomass sources (based on Buffi et.al 2022)
Biohydrogen can be produced through several conversion routes, using a wide range of biogenic feedstocks.
Feedstock options vary from low-grade materials (wastewater, forestry and agricultural residues) to higher quality feedstocks (bioethanol, biomethane).
Many production concepts deliver additional co-products, such as biochar, biocarbon, or biomethane, and in some cases CO₂ streams that could enable negative emissions.
Case studies provide detailed assessments of technology readiness, economic fundamentals, climate impacts, and their potential role in the energy system.
✅ Status of development
All production concepts examined remain at the development stage (TRL 4–7) and none has yet reached full commercialization.
The report highlights both the opportunities and the barriers for scaling these technologies.
☑️ Takeaway
While biohydrogen will not play a role in fulfilling RED III targets for RFNBO, it may provide complementary pathways for decarbonisation and resource efficiency, particularly if integrated into biobased value chains with multiple outputs.
