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

Tag Archives: #PtX

Author Image Posted By : admin 28 Dec, 2025

Germany’s national Power-to-Liquid quotas

Germany’s national Power-to-Liquid quotas

As part of my research, I closely follow recent developments regarding Germany’s national Power-to-Liquid (PtL) quotas for aviation and would like to share the key updates with you.

🔹 What do PtL quotas mean?

Power-to-Liquids (PtL) refers to liquid hydrocarbons produced using electricity, water, and CO₂ as inputs. Based on these characteristics, PtL quotas cover targets and obligations for hydrogen-based fuels, such as e-SAF for aviation.

🔹 What happened in Germany?

  • In September 2021, Germany adopted ambitious PtL quotas for aviation through amendments to the Federal Immission Control Act (BImSchG).
  • These mandatory national quotas required a minimum share of RFNBOs in aviation fuel of:
    • 0.5% in 2026
    • 1% in 2028
    • 2% in 2030.
  • The basis for adopting such ambitious quotas was the German PtL roadmap for aviation fuels, published in April 2021.
  • However, these national PtL quotas were more ambitious than those established under the ReFuelEU Aviation Regulation, which introduces a minimum PtL sub-quota only from 2030 onwards.
  • As a result, the European Commission opposed the German national quotas, emphasizing the binding nature of ReFuelEU Aviation as an EU regulation that replaces national PtL quotas for aviation.

🔹 How was this PtL quota issue resolved?

  • In October 2024, the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) announced revisions to the national PtL quotas for aviation.
  • In June 2025, BMUV published the Draft Law for a Second Law on the Further Development of the GHG Reduction Quota (the Draft Law on the GHG Reduction Quota), proposing the removal of national PtL quotas for aviation from the BImSchG.
  • In December 2025, the national PtL quotas for aviation were formally abolished through the Draft Law on Accelerating the Expansion of Geothermal Energy Plants, Heat Pumps and Heat Storage Facilities, and on Amending Other Legal Framework Conditions for the Climate-Neutral Expansion of Heat Supply.

➡️ The German PtL quota will expire on January 1, 2026.

✅ What’s next?

The PtL quotas for aviation are included in the Draft Law on the GHG Reduction Quota and will be based on the minimum share of e-SAF set out in the ReFuelEU Aviation Regulation.

If you have any questions about PtL quotas, I’d be happy to discuss them.

🔗 The Draft Law: Gesetz zur Beschleunigung des Ausbaus von Geothermieanlagen, Wärmepumpen und Wärmespeichern und zur Änderung weiterer rechtlicher Rahmenbedingungen für den klimaneutralen Ausbau der Wärmeversorgung sowie zur Änderung des Baugesetzbuchs und zur Änderung des BundesImmissionsschutzgesetzes

🔗 Source: Bundesrat beschließt Abschaffung der nationalen PtL-Quote

Author Image Posted By : admin 24 Aug, 2025

The Origins of Power-to-X concept

Sector coupling resulted from Power-to-Gas and Power-to-X. It links the sectors of electricity, heat, transport and industry via energy storage and energy converters and using renewable electricity as ‘primary energy’ for ecarbonization. Power-to-Heat, Power-to-Gas, Power-to-Liquid, Power-to-Chemicals, Power-to-Products.

Figure: Sector coupling resulted from Power-to-Gas and Power-to-X

Source: Sterner, M.; Stadler, I. Handbook of Energy Storage: Demand, Technologies, Integration; Springer: Berlin/Heidelberg, Germany, 2018; ISBN 978-3-662-55503-3

The term “Power-to-X” is now widely used in the energy sector. This concept is less than 20 years old.

The idea of producing fuels from renewable electricity emerged in Germany in the early 2010s. What began as Power-to-Gas (PtG) has since evolved into the broader Power-to-X (PtX) approach.

✅ Key milestones in its development:

📌 2008 – Integrated Energy System Concept:

  • Coupled electricity and gas with CO₂ sinks;
  • Introduced Power-to-Gas via electrolyzers producing green hydrogen.

📌 2008 – European Biomass Conference:

  • Presented integrated electricity-gas-CO₂ systems;
  • Proposed the Sabatier process for CO₂ methanation instead of the reformer for the better integrability of hydrogen in the natural gas grid.

📌 2009 – Breakthroughs:

  • Patent application for PtG, first PhD thesis on the topic, and
  • The PtG plant for CO2 methanation – SolarFuel GmbH.

📌 2013/14 – Shift to Power-to-X:

  • The concept was expanded beyond gas to include fuels, chemicals, and heat — enabling decarbonization where direct electrification isn’t enough.

🎯 Main Purpose of PtX: To store renewable energy and decarbonize hard-to-electrify sectors through fuels, chemicals, and other energy carriers.

➡️ Source: Sterner M., Specht M. “Power-to-Gas and Power-to-X – The History and Results of Developing a New Storage Concept”

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.