News

Revisions to CBAM regulation

CBAM: downstream extensions, anti-circumvention and rules on electricity emissions

For general information about CBAM please visit General Introduction to CBAM.

This July, the European Commission launched a public consultation on proposed revisions to CBAM. The key aims:

Extend CBAM to certain downstream products – to reduce the risk of carbon leakage when production shifts outside the EU or buyers turn to non-EU suppliers.
Strengthen anti-circumvention measures – to close gaps and ensure the financial obligations are not avoided without valid reasons.
Clarify electricity-related rules – particularly the use of default values and criteria for using actual electricity emissions.

📅 Feedback period – 01 July 2025 – 26 August 2025

✅ Main Objectives of Consultation

The consultation explores:

📌 Inclusion of selected downstream goods based on carbon leakage risk, embedded emissions, and technical feasibility.

📌 Options to reinforce anti-circumvention tools (e.g. more reporting requirements).

📌 Changes to CBAM rules for electricity – from emission factor updates to clearer criteria for PPAs and grid conditions.

☑️ What next?

A factual summary report will be available 8 weeks after the consultation closes, followed by a full synopsis report.

➡️ Source: Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions

Posted By : admin 21 Jul, 2025

News on the Hydrogen and Guarantees of Origin Market

hydrogen and guarantees of origin (GO) system

The latest EU report titled “Technical assistance to monitor functioning of the guarantees of origin (GO) system” provides an in-depth look at the GOs market and its impact on renewable energy and hydrogen tracking.

✅ Key Takeaways

📌 The GO market has achieved a healthy level of liquidity.

📌 While transparency has improved, price discovery remains limited. GO prices vary based on factors such as technology, region, and additionality – factors not always visible to consumers. Forecasting prices remains difficult due to elements of monopolistic competition.

📌 More than 90% of hydropower, 50% of wind, and 30% of solar electricity production in Europe is currently tracked via GOs.

📌 The GO system is effective in tracking renewable electricity, but further harmonization is needed to reduce the risk of misuse.

📌 Hydrogen

As of the end of 2023: only 0.4% of EU hydrogen production was based on water electrolysis (45 tonnes or 1.5 GWh).
An additional 9.2% (1,033 tonnes or 34 GWh) was produced as a green by-product (e.g., from chlor-alkali electrolysis).
The Hydrix index (as of January 2025) estimates green hydrogen prices in Germany at €7.80–€9.50/kg, roughly 2.5x higher than grey hydrogen (€3–€4/kg).

📌 Hydrogen GO trading volumes

RFNBO certification has only been possible since December 2024.
Until now, certified green hydrogen has only been traded via GOs or Non-Governmental Certificates (NGCs).
Assuming certification, 1,500 GOs could have been issued in 2023 for hydrogen produced via electrolysis.
While only a few EU Member States are active in the gas GO market and even fewer support EU-wide GO trading, interest in GOs is growing:
- Smaller projects often opt for GOs/NGCs due to lack of RFNBO compliance.
- Larger projects (many pre-FID) are preparing for RFNBO certification to benefit from offtake obligations under the compliance market.

➡️ Source: Technical assistance to monitor functioning of the guarantees of origin (GO) system

Posted By : admin 18 Jul, 2025

Interaction of Certification and Standards for e-SAF Production

Last week, I had the opportunity to present my paper “Interaction of Certification and Standards for e-SAF Production” at a conference hosted by the Florence School of Regulation. This research is part of my broader PhD work on the interaction between law and technology in the regulation of Power-to-X (PtX) technologies.

✅ Key Points of the Presentation:

📌 General requirements

To be used in aviation, e-SAF must be certified under either the EU Renewable Energy Directive (RED) or the CORSIA scheme, and blended with conventional jet fuel in accordance with international standards such as ASTM D7566 and Def Stan 91-091.

📌 Legal Framework

There is a lack of harmonization between the EU legal framework and international aviation fuel standards.
The definition of SAF in the ReFuelEU Aviation Regulation does not align with the definition used in international standards.

📌 Certification

Particular attention should be given to the concept of “dual conformance” — i.e., a single batch of SAF being compliant with two different certification schemes (such as EU RED and CORSIA).
The coexistence of two certification schemes – EU RED and CORSIA within the EU raises questions about the feasibility of such dual conformance, a concept that is not yet defined under EU law.

☑️ Conclusion

A harmonized and coherent legal framework is essential for scaling up e-SAF production and deployment in aviation.
Aligning EU regulations with international safety and sustainability standards will help remove existing regulatory barriers and support the widespread adoption of e-SAF across the EU.

Maryna Hritsyshyna. Interaction of certification and standards for e-SAF production

GHG Emissions: aviation emits about 3% of global carbon dioxide, about 96% of GHG emissions in aviation belong to the large airplanes.
Sustainable aviation fuel: a solution for medium and long-haul airplanes, allow reducing carbon emissions by 50-80% in comparison with the conventional fuel.

Posted By : admin 17 Jul, 2025

Association of Issuing Bodies Annual Report 2024

Figure: Association of Issuing Bodies members, applicants and observers

Source: Association of Issuing Bodies, Annual Report 2024

📢 The Association of Issuing Bodies (AIB) Annual Report 2024 is out!

✅ Key highlights from 2024:

📌 Membership Expansion

By the end of 2024, the AIB had 39 members from 30 European countries, covering the EU, EEA, and Energy Community.

📌 Electricity Guarantees of Origin

30 members actively participated in the European Energy Certificate System (EECS) Electricity Scheme, issuing and transferring GOs via the AIB Hub.
New participants preparing for the scheme:
- NEURC (Ukraine)
- ERE (Albania)
- SEDA (Bulgaria)

New observers:
- ERO (Kosovo)
- MEMO (North Macedonia)

📌 Gas Guarantees of Origin

9 members were active in the EECS Gas Scheme, including:
- Gasgrid (Finland)
- Enagas (Spain)
- Brugel (Belgium)
- E-Control (Austria)
- GSE (Italy)
- REN (Portugal)
- OTE (Czech Republic)
- Elering (Estonia)
- Conexus (Latvia)
2024 was a milestone year for the Gas Scheme Group, with six new members joining.

📌 Hydrogen

In 2024, the following countries registered EECS hydrogen production devices:

Austria: 2 devices (10 MW total capacity)
Finland: 1 device
Spain: 2 devices (23.8 MW total capacity)

It’s great to see steady progress across electricity, gas, and now hydrogen, contributing to a more integrated and transparent GO market across Europe.

➡️ The AIB Annual Report is available via this link: ANNUAL REPORT 2024

Posted By : admin 16 Jul, 2025

Hydrogen Acceleration Act

Last week, the Federal Ministry for Economic Affairs and Energy (BMWK) presented the Draft Law for a new Hydrogen Acceleration Act (Wasserstoffbeschleunigungsgesetz).

📄 The Draft Law is available via this link.

✅ Key Points:

📌 Broader Scope Beyond Green Hydrogen

Unlike previous strategies focused solely on green hydrogen, the new Draft Law grants equal treatment to both green and blue hydrogen.
Projects producing blue H2 from natural gas with carbon capture and storage (CCS) may now benefit from acceleration measures.

📌 Support Across the Entire Hydrogen Value Chain

The Act aims to fast-track:

Electrolyser deployment
Hydrogen imports and derivatives (e.g., ammonia, methanol)
PtX plants for e-fuel production
Hydrogen storage and transport infrastructure

📌 Natural Hydrogen Recognition

Natural hydrogen will be classified as a non-mineable mineral resource under the Federal Mining Act (Bundesberggesetz).
This change simplifies project development by removing the need for contracts with landowners—similar to how resources like coal or natural gas are handled.

📌 Accelerated Permitting

No public hearing (Erörterungstermin) will take place during the approval process.
A planning approval decision (Planfeststellungsbeschluss) must be issued within 12 months.
A planning permit (Plangenehmigung) must be granted within 7 months.

📅 Consultation Period:

The BMWK is accepting feedback from federal states and industry associations until 28 July 2025.

Posted By : admin 15 Jul, 2025

Nuremberg Hydrogen Conference 2025

On 14 July 2025, I had the pleasure of attending the Nuremberg Hydrogen Conference, hosted by the University of Technology Nuremberg.

The event brought together leading researchers, policymakers, and industry representatives to discuss the current state and future of the hydrogen economy in Germany and beyond.

✅ Key takeaways:

📌 AI and clean energy:

The growing energy demands of AI make clean hydrogen a key enabler for a sustainable digital future.

📌 Speed of integration:

While oil and gas took ~50 years and renewables ~15 years to become integral to the energy system, hydrogen should achieve this in just 5 years — provided the right conditions are in place.

📌 Hydrogen production costs (2023, EU grid-mix):

Lowest: Finland (€4.1/kg), Sweden (€4.4/kg)
Highest: Cyprus (€17.4/kg), Poland (€12.4/kg)

📌 Barriers slowing hydrogen deployment:

Limited willingness to pay for H2
Market uncertainty and lack of demand aggregation
Permitting delays
Industry is still waiting for GW-scale proof and strong public support mechanisms.

📌 Hydrogen imports remain slow, and it is important to create competition between demand and production side.

📌 A clear market dynamic: as hydrogen prices rise, demand drops – and vice versa.

📌 Two-sided auctions, such as those facilitated by H2Global, are a promising tool to stimulate both supply and demand and accelerate market ramp-up.

Posted By : admin 11 Jul, 2025

2nd Florence Aviation Regulation Conference

Just returned from the 2nd Florence Aviation Regulation Conference, co-organized by the International Institute of Air and Space Law (IIASL), Leiden University and the Florence School of Regulation.

It was an honor to contribute to such a high-level exchange of ideas shaping the future of aviation regulation.

I had the pleasure of presenting my paper on “Interaction of Certification and Standards for e-SAF Production”, exploring how regulatory frameworks and technical standards impact the uptake of sustainable aviation fuels in Europe.

The conference addressed a wide range of topics, including:

Interaction between CORSIA and the EU ETS
Implementation of the AI Act in aviation
Market incentives and social sustainability in the net-zero transition
Regulation of non-CO₂ effects in aviation

Posted By : admin 9 Jul, 2025

Delegated act for Low-Carbon Fuels

📢 New EU Regulation on Low-Carbon Hydrogen and Fuels

On 8 July 2025, the European Commission adopted a Delegated Regulation specifying the methodology for calculating GHG emissions savings from low-carbon fuels, including low-carbon hydrogen (the Delegated Act).

✅ What is this about?

The Delegated Act establishes a GHG emissions methodology for low-carbon hydrogen and fuels, as outlined in the Hydrogen and Gas Market Directive.
It complements existing rules on renewable hydrogen and RFNBOs, creating a complete EU regulatory framework for hydrogen certification.

☑️ Who does it apply to?

The Delegated Act applies to EU and non-EU producers wishing to place hydrogen on the EU market.
Certification can be achieved through Voluntary Schemes — third-party systems already in use for renewable fuels.

📅 What happens next?

The Delegated Act will now be reviewed by the European Parliament and Council, who have 2 months to accept or reject it.
This scrutiny period may be extended by an additional 2 months, if requested.
If approved, the Delegated Act will enter into force 20 days after its publication in the Official Journal of the EU.

📄 Delegated Act: Commission delegated regulation (EU) specifying a methodology for assessing greenhouse gas emissions savings from low-carbon fuels

➡️ Source: Clarity to hydrogen sector with new EU methodology for low-carbon hydrogen and fuels

Posted By : admin 7 Jul, 2025

Bringing Hydrogen to the EU Market

In this episode of Clean Energy Talks video blog with Joris Vlasblom, an experienced energy advisor specializing in hydrogen, renewable energy, and Sustainable Aviation Fuel (SAF), we talk about bringing hydrogen to the EU Market:

I. EU Hydrogen Targets & Demand

How do you assess the current demand for hydrogen and its derivatives in the EU?

How aligned is the current market demand with the EU’s hydrogen targets for 2030 and beyond?

II. Market Entry & Readiness

What are the biggest challenges to bringing hydrogen into the EU market today?

III. Certifications & Standards

How can producers confirm the compliance of hydrogen with EU market requirements?

How crucial is the RFNBO certification for accessing the EU market?

IV. Infrastructure & Technology

What infrastructure gaps (e.g. ports, pipelines, storage) are most urgent to address?

V. Practical Solutions

What are some practical steps companies should take when planning to enter the EU hydrogen market?

➡️ Reach out here on LinkedIn or contact me for more details on the video topic.

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

Energy Regulation Solutions

About us

✅ Key Takeaways

📌 Hydrogen

📌 Hydrogen GO trading volumes

📌 General requirements

📌 Legal Framework

📌 Certification

☑️ Conclusion

📌 Membership Expansion

📌 Electricity Guarantees of Origin

📌 Gas Guarantees of Origin

📌 Hydrogen