The future of hydrogen standards is modular

The “harmonization,” “interoperability” and “mutual recognition” of hydrogen standards is a hot topic these days. It would be great if there was a single, comprehensive standard that had the full support of all stakeholders. Instead, a recent review by the IEA highlights the growing fragmentation of hydrogen standards. Countries are adopting different positions on “system boundaries” and emissions thresholds. Some focus exclusively on emissions measurement, whereas others address a wider set of social and environmental considerations. Standards also differ widely across different industries and hydrogen use cases. Even within the EU, for example, there are different approaches to hydrogen standards in the transportation, maritime, aviation and industrial sectors. The IEA warns that this fragmentation is undermining the development of international hydrogen trade.  

The good news is that there is an emerging global consensus on how to measure greenhouse gas emissions from different hydrogen production pathways. This work has been led by the International Partnership for Hydrogen and Fuel Cells in the Economy (IPHE), and work has commenced on codifying this method as an ISO standard. A key problem is that this work dodges an essential question. Most of the hydrogen produced today results in very large greenhouse gas emissions (often > 10 kilograms of CO2e for every kilogram of hydrogen). With the hydrogen industry expected to grow by 500% or more in the next 30 years, it is essential to agree on a threshold for greenhouse gas emissions that is aligned with national and global climate commitments to limit global warming to 1.5 degrees. However, the IPHE and the ISO are not addressing this question. Hydrogen certification schemes that follow this approach risk validating unsustainable projects and enabling greenwashing since they might simply claim to have been assessed under IPHE/ISO which could lend a veneer of credibility to the project even if it results in high emissions.  

In the figure below, we illustrate the fragmentation of hydrogen standards. 

Most would agree that hydrogen emission standards should be comprehensive, covering the full value chain from production all the way through to end use. But this is not how most standards are designed. Some focus solely on the “point of production,” ignoring upstream and downstream emissions. Others are more ambitious, covering “well-to-wheel” or “well-to-point of delivery” emissions, but even these standards neglect important greenhouse gas emissions, including emissions associated with final use and embodied emissions right along the value chain.  

Hydrogen standards need to cover a range of products and derivatives (like ammonia, ethanol and SAF) and the treatment of co-products (like oxygen and CO2). It makes “like-for-like” comparisons challenging. Generally, no single entity controls the whole value chain, so verifying life cycle emissions requires collaboration between several parties.  

As countries and companies develop their hydrogen strategies, their approach to hydrogen standards usually reflects their circumstances and comparative advantages. When you have a vested interest in a particular resource or technology, there is a strong incentive to push for a standards framework (a “system boundary”) that casts your preferred technology in the best light.  

To overcome this fragmentation, we need to stop thinking about a single, comprehensive standard that will be centrally validated. Instead, we need to break the problem up into modules and use open data standards so that producers, customers, and regulators can share information along the value chain and across jurisdictions.  

A modular approach to hydrogen standards and certification  

GH2’s Green Hydrogen Standard™ takes a modular approach to hydrogen standards. Our approach is based on three key principles. 

First, any system for labelling and tiers must be clearly aligned with national and global climate commitments to limit global warming to 1.5 degrees. For hydrogen to fulfil its promise to address climate change and decarbonise key sectors of our economy like steel and shipping, emissions need to trend towards near zero by 2030. The Green Hydrogen Standard is modular, but this does not mean that “anything goes.” The Standard has a set of minimum requirements that always have to be met, including the emissions thresholds of 1kg for hydrogen and 0.3kg for ammonia.  

Second, we are committed to a full life cycle analysis (LCA) of greenhouse gas emissions, including embedded emissions. Our emissions thresholds for green hydrogen and green ammonia are based on a “well to gate” methodology in line with the IPHE. However, the Standard also expects project operators to calculate and report on the emissions associated with the storage, conversion and delivery of hydrogen and its derivatives and encourages project operators to calculate and report on embodied emissions. The GH2 Board has committed to review the performance of GH2 accredited projects on an annual basis, with the expectation that the boundaries of the emissions assessment framework can be widened, and that the emissions thresholds will be lowered in accordance with emerging best practice.  

Third, we are committed to high levels of transparency and disaggregated reporting to increase confidence and promote accountability. Our accreditation and certification methodology goes beyond verifying that the 1kg (hydrogen) and 0.3kg (ammonia) thresholds are met over a 12-month period. This is the minimum requirement for accreditation. In addition, project operators need to demonstrate that they have robust systems for measuring emissions on a more granular basis. For each tonne of production, GH2 certification will verify the emissions. The certification system that we are developing includes an option to disaggregate the data into different production stages, and to provide other data where available, including verifying temporal matching, estimates of embodied emissions and emissions from transportation and storage. 

A good example of this is our work to align GH2 accreditation with the EU’s definition of “renewable hydrogen” in the transportation sector (which will also apply to imports into the EU). The EU rules (see here) require that new additional renewable electricity is deployed to produce green hydrogen and that the renewable electricity is matched with electrolysers in terms of timing and location. The rules include a transition period where “additionality” and a number of state aid restrictions are waived for projects which begin production before 2028, and hydrogen production only needs to be matched with renewable electricity on a monthly basis until 2030, at which point it will shift to hourly matching. The carbon intensity of green hydrogen produced in this way must be <3.4 kg of CO2e per kg of hydrogen on a “well-to-wheel” basis (i.e., including the storage, conversion and delivery of hydrogen and its derivatives). To address these requirements, GH2 accreditation and certification will include an option to verify adherence to the EU’s requirements at the point of production. The information can then be combined with other data to verify adherence to the EU’s “well-to-wheel” requirements.  

Transparency is the key! 

It is not sufficient to brand your product as “green hydrogen,” “clean hydrogen” or “low carbon hydrogen.” As my maths teacher Mr Chalk used to say: “you have to show your work.” When it comes to emissions associated with hydrogen, this means disaggregated reporting of emissions at each step in the process so that there is no information loss as the commodity makes its way from producer to consumer. It is also why a strong proof of origin system is needed, such as mass balancing, so that hydrogen can be traced with integrity to consumers. More detailed information will help producers with the lowest emissions secure the support needed from customers, investors, government agencies and the communities that host these projects.