Realism at the end of the rainbow? An argument towards diversifying hydrogen in EU regulation

Abstract

Abstract The European Union’s (EU) decarbonization strategy involves hydrogen as an integral pillar. Since hydrogen is a secondary energy carrier, meaning it must be manufactured, not all hydrogen is made equal. Renewable hydrogen or RFNBOs (Renewable Fuel of Non-Biological Origins) have been given high priority by the EU in their strategy to establish a market for hydrogen. The EU’s creation of RFNBO usage objectives is a step towards establishing a demand-side market. One such goal is to bring into the EU up to 10 million tonnes of renewable hydrogen. However, it is doubtful that this large amount can be reached given the strict criteria for what qualifies as renewable hydrogen and, thus, as RFNBO. This article analyses key provisions of the EU framework that affect the EU’s aim to produce and import up to 20 million tonnes of hydrogen overall. It concludes the EU’s emphasis on RFNBOs rather than a broader range of hydrogen pathways undermines the goal of rapidly developing a hydrogen market. Using turquoise hydrogen as a case study, the article shows how the EU’s decarbonization efforts would be aided, trade would be enabled, and fragmentation would be decreased if targets were expanded to encompass additional forms of hydrogen.