EU Low-Carbon Hydrogen production rules are not the signal investors were waiting for
Brussels, 11 July 2025: The much-awaited methodology for hydrogen production is not the enabler investors need to scale up the European hydrogen market. By imposing overly prescriptive and impractical rules, the Act risks discouraging investment decisions for planned and new projects, undermining Europe’s industrial decarbonization goal, and jeopardizing the EU’s own hydrogen ambition.
Investors’ recommendation to use real-world project data was not taken into account, and the methodology risks discouraging investments by forcing investors to use default values that artificially inflate their projects’ emission profile, preventing them from being recognized as ‘low-carbon hydrogen’.
Key production pathways may therefore be discarded not because of their real emissions, but because of a methodological choice. In addition, it introduces a distinction between gas sourced via pipeline and LNG for the production of hydrogen, which raises traceability concerns.
Unfortunately, the lack of a grandfathering clause adds significant uncertainty for investors as it opens the door for future, unforeseen changes to the methodology, which may disqualify future projects.
IOGP Europe calls on the co-legislators to request an extension of the scrutiny period, and on institutions to establish a regulatory framework that effectively enables, not hinders, the scale-up of key hydrogen production pathways essential to the decarbonization and competitiveness of European industry.
“The European Commission had the opportunity to send a strong signal to clean hydrogen investors and consumers across Europe. Instead, this Act introduces rigidity, complexity, and uncertainty; three elements that risk delaying investment decisions and ultimately the transition itself.’’
François-Régis Mouton, Managing Director of IOGP Europe.
Read IOGP Europe’s detailed recommendations: EU Hydrogen Strategy needs a fundamental reset.
About IOGP Europe
IOGP Europe is the European and advocacy arm of the International Association of Oil & Gas Producers (IOGP), the leading voice of the global oil and gas industry, pioneering excellence in safe, efficient and sustainable energy. We represent around 30 energy companies, accounting for 70% of EU oil & gas production. We support policymakers in crafting impactful and inclusive policies that drive prosperity for Europe's businesses and citizens.
Contact
Nareg Terzian
Head of Strategy and Communications
Email: gro.p1752532704goi@z1752532704tn1752532704
www.iogpeurope.org
- Publications
- Press Releases
- Events

EU Low-Carbon Hydrogen production rules are not the signal investors were waiting for

IOGP Europe response to consultation on the Industrial Decarbonisation Accelerator Act (IDAA) and call for evidence

IOGP Europe’s response to the public consultation on the evaluation of Innovation Fund’s operation

Press release: State Aid Framework for Clean Industrial Deal marks a turn towards pragmatic decarbonization

IOGP Europe’s response to ESMA consults on clearing thresholds under EMIR 3

Joint statement: Urgent need for European Commission to correct course on the draft Delegated Regulation on Low Carbon Fuels

The upcoming Grids Package: a critical opportunity not to be missed for the deployment of a European hydrogen infrastructure

Unlocking the Black Sea’s Strategic Energy Potential

EU Hydrogen Strategy needs a fundamental reset

IOGP Europe’s response to the call for evidence on Modernisation Fund’s operating rules

Response to the European Commission’s consultation on the draft Clean Industrial Deal State Aid Framework (CISAF)

Public consultation on inter-temporal cost allocation mechanisms (ICA) for financing hydrogen infrastructure

IOGP Europe views on Communication on the Action Plan for Affordable Energy

Advancing a Competitive, Resilient, and Integrated Energy Market

IOGP Europe Response to the Consultation on the Review of the Taxonomy Climate Delegated Act

Joint Statement: Reality Check for European Hydrogen Policy to Adjust the Course

The Case for a European CCS Bank

The Joint Statement on the Low-Carbon Fuels certification draft Delegated Act

IOGP response to the public consultation on the draft Methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels

Joint Statement on the Low-Carbon Fuels certification Delegated Act

GasNaturally Letter to Competitiveness Council 23 May 2024

IOGP Europe recommendations on the Delegated Act specifying a methodology for assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen

IOGP response on Competitive Bidding schemes for hydrogen under the Innovation Fund

IOGP response on revamping the Strategic Energy Technology (SET) Plan

IOGP views on the proposed Regulation amending Regulation (EU) 2021/241 as regards REPowerEU chapters in Recovery and Resilience Plans

IOGP response to the public consultation on the Hydrogen and Decarbonized Gas Market package

IOGP comments to R. W. Howarth and M. Z. Jacobson (2021): How Green is Blue Hydrogen?

Re-Stream – Study on the reuse of oil and gas infrastructure for hydrogen and CCS in Europe

IOGP Paper on metric to use for 2030 targets

IOGP input to the consultation on the Hydrogen and Gas Market Decarbonization Package

What’s Right? What’s Wrong? IOGP comments on the ‘EU Strategy for Energy System Integration’ and ‘A hydrogen strategy for a climate neutral Europe’

IOGP input to the Roadmap on the EU Smart System Integration

IOGP input to the Roadmap on the EU strategy on hydrogen in Europe

IOGP feedback to the Combined Evaluation Roadmap/Inception Impact Assessment on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E

IOGP input to the forthcoming EU Strategy for Energy System Integration

New and old CCS projects in Europe: What’s different this time?

Scaling up Hydrogen in Europe

Hydrogen for Europe Pre-study – Key findings

Hydrogen for Europe

The potential for CCS and CCU in Europe Report to the thirty second meeting of the European Gas Regulatory Forum 5-6 June 2019

Press release: 2040 Climate trajectory requires urgent action on policy enablers

Press release: State Aid Framework for Clean Industrial Deal marks a turn towards pragmatic decarbonization

Press release: Low-carbon fuels methodology envisaged by the Commission will block key hydrogen production pathways

Draghi Report: a pragmatic pathway to Competitiveness, Sustainability, and Resilience

Press release: Recognition of CCS on path to 2050 marks a step change, but approach to low-carbon solutions remains too narrow.

Net-Zero Industry Act marks a step change in industrial and climate policy – EU paves way for carbon capture and storage scale-up

Gas market reform marks a step change in EU approach to the transition

New Re-Stream study assesses the feasibility of transport of hydrogen and CO2 in European gas and oil infrastructure

Council’s inclusive approach to hydrogen sends strong signal ahead of key legislative year

EU’s hydrogen and energy system vision can only succeed with a more balanced, inclusive approach

The Europe CCUS & Hydrogen Decarbonisation Summit

Re-Stream Study Launch Event

Hydrogen4EU Launch Event

Sustainable finance: investor, oil and gas sector and global perspectives

Carbon Management Webinars

Sustainable finance: non-financial disclosure for the oil and gas sector and EU taxonomy in practice
