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.

βœ… Key Takeaways

πŸ“Œ The GO market has achieved a healthy level of liquidity.

πŸ“Œ 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.

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

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

πŸ“Œ 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).

πŸ“Œ 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.

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

Association of Issuing Bodies Annual Report 2024

Association of Issuing Bodies members, applicants and observers

Figure: Association of Issuing Bodies members, applicants and observers

Source: Association of Issuing Bodies, Annual Report 2024

πŸ“’ The Association of Issuing Bodies (AIB) Annual Report 2024 is out!

βœ… Key highlights from 2024:

πŸ“Œ Membership Expansion

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

πŸ“Œ 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)

πŸ“Œ 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.

πŸ“Œ 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.

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

Hydrogen Acceleration Act

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).

πŸ“„ The Draft Law is available via this link.

βœ… Key Points:

πŸ“Œ 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.

πŸ“Œ 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

πŸ“Œ 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 landownersβ€”similar to how resources like coal or natural gas are handled.

πŸ“Œ Accelerated Permitting

  • No public hearing (ErΓΆrterungstermin) 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.

πŸ“… Consultation Period:

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

Nuremberg Hydrogen Conference 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.

βœ… Key takeaways:

πŸ“Œ AI and clean energy:

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

πŸ“Œ 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 β€” provided the right conditions are in place.

πŸ“Œ 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)

πŸ“Œ 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.

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

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

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

Delegated act for Low-Carbon Fuels

EU Regulation on Low-Carbon Hydrogen and Fuels

πŸ“’ 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).

βœ… 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.

β˜‘οΈ 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 β€” third-party systems already in use for renewable fuels.

πŸ“… 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.

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

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

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?

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

Clean Industrial Solutions and Aid Framework (CISAF)

πŸ“’ On 25 June 2025, the European Commission adopted the Clean Industrial Solutions and Aid Framework (CISAF) β€” 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.

πŸ”Ή 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.

πŸ”Ή 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.

βœ… 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.

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

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

πŸ“’ 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: β€œIn Search of the Real Price of Blue Hydrogen”, available via this link.

βœ… Key Takeaways from the report:

πŸ“Œ 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 COβ‚‚ storage

πŸ“Œ Carbon capture performance is inconsistent

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

πŸ“Œ 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.

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

➑️ Source: Commission’s draft rules make low-carbon hydrogen β€˜practically impossible’, say stakeholders

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).

βœ… The main changes:

πŸ“Œ 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.

πŸ’§ 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.

πŸ“Š 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 Β§ 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.

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

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.

βœ… Key Takeaways:

πŸ“Œ 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.

πŸ“Œ Location Matters

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

πŸ“Œ 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.

πŸ“Œ Flexibility Potential

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

πŸ“Œ 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.

πŸ“Œ 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.

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