Letter to the European Comission: Ensuring third country green hydrogen suppliers can support Europe to meet its energy security and decarbonisation ambitions

February 21, 2025

 

Dear Executive Vice-Presidents Ribera and Séjourné,  

Dear Commissioners Jørgensen and Šefčovič, 

Ensuring third country green hydrogen suppliers can support Europe to meet its energy security and decarbonisation ambitions 

The Clean Industrial Deal due to be launched on Wednesday, 26 February, is a major opportunity for Europe to capitalise on the partnerships needed to enhance its competitiveness, energy security and decarbonisation ambitions. 

Many companies including Adani, AM Green, CWP Global, Fortescue, Hero Future Energies, and Hygenco with plans for large scale production of renewable green hydrogen and associated derivatives such as green ammonia and methanol wish to support Europe in reaching its targets for renewable green hydrogen.                                                                                                                                                                                                                                       

We would like to emphasise the following key points ahead of the launch of the Clean Industrial Deal. 
 

  1. We call on the EU not to dilute the targets under RED III by expanding support for “low carbon” hydrogen made with fossil fuels. The EU is seen as a key destination for green hydrogen products due to the demand mandates for green hydrogen introduced under the Renewable Energy Directive (REDIII) where industrial users of hydrogen must use 42% green hydrogen instead of unabated fossil-based grey hydrogen by 2030 as well as the 1% sub-target for transport and associated targets in FuelEU Maritime and ReFuelEU Aviation which are driving demand. It is essential not to dilute these existing targets through new exemptions or by setting separate low-carbon fossil hydrogen targets. This would be hugely damaging due to the risk of perpetuating fossil fuel use rather than driving a renewables transition; concerns that standards for measuring the full life cycle emissions intensity of ‘low carbon’ fossil hydrogen severely underestimate actual emissions; the specific need for targets and support for renewable green hydrogen to drive scale, efficiency and cost reductions which do not apply to fossil-based blue hydrogen where cost will always be linked to gas price volatility; and the energy security benefits of green hydrogen through domestic production and diverse import opportunities.   
     
  2. We call on the EU not to modify the RFNBO Delegated Acts: while we are open to extending the transition period for RFNBO conditions, we have spent two years preparing projects on the basis of the February 2023 RFNBO Delegated Acts. Changing the criteria defining RFNBOs now would bring uncertainty and potentially undermine significant decarbonisation efforts already under way. The challenge our industry is facing relates to customer demand rather than the definition of RFNBOs. Swift and effective member state implementation of the RED III targets should be the focus in order to drive demand. 
     
  3. We call on the EU to urgently open the international pillar of the European Hydrogen Bank and enhance support for lead markets. The second round of the European Hydrogen Bank’s domestic pillar launched in December 2024, but we are yet to see funding provided for the international pillar. The H2Global scheme which also subsidise the purchase of green hydrogen and derivatives from third countries via an intermediary has shown much promise and we see important synergies to linking both schemes under the European Hydrogen Bank for imports, and to the recent signals supporting lead markets such as steel and fertilisers in the EU. As with the RED III targets, we implore the Commission to ensure funding support remains limited to RFNBO compliant hydrogen, and not introduce financial support for ‘low carbon’ fossil hydrogen. 
     
  4. We call on the EU to clarify the concept of “bidding zone” for third countries. While the European Commission allows for “equivalent concepts [to “bidding zone”] provided the objective of this Regulation is maintained and the provision is implemented based on the most similar concept existing in the third country concerned”, third country producers would benefit from the ability to confirm with the European Commission which equivalent concepts are acceptable by country. This enhanced certainty would lower the investment risk associated with our multibillion Euro projects. 
     

As third country producers, we stand ready to support Europe to reach its energy security and decarbonisation objectives. The recommendations contained in this letter would greatly improve our ability to do this and enhance key trade partnerships. Now is the time to hold the line rather than water down the impressive mandates for renewable energy and green hydrogen which have been established. To do so would threaten the existence of our nascent sector.  
 

Sincerely,         

Jonas Moberg 
CEO 
Green Hydrogen Organisation