Press release: Low-carbon fuels methodology envisaged by the Commission will block key hydrogen production pathways
Brussels, 27 May 2025: The draft Delegated Act laying out the methodology for low-carbon hydrogen production will stop or, at best, put on hold even the best-performing projects planned or under development to supply Europe. This will deprive European energy-intensive industries of a scalable, clean, and affordable source of hydrogen.
The draft methodology put forward by the European Commission presents four key challenges:
- It artificially inflates the reported emissions of hydrogen produced via methane reforming with Carbon Capture and Storage, by requiring blue hydrogen producers to apply conservative default CO2 emission values rather than using actual values based on verified measurements.
- It severely constrains the use of methane pyrolysis due to prescriptive co-product requirements, effectively limiting the development of the technology before its development.
- It undermines the level playing field between Steam Methane Reforming (SMR) and Autothermal Reforming (ATR) technologies through requirements that risk undermining investments in state-of-the-art ATR technologies.
- Lacks clarity on using biomethane as a partial replacement for natural gas to lower the intensity of feedstock processing.
“This Delegated Act is meant to encourage project developers to take Final Investment Decisions. The current draft will achieve the opposite by stopping projects in their tracks. We need a clear, pragmatic, and technology-neutral approach that allows the hydrogen economy to take off in Europe,” said François-Régis Mouton, Managing Director, IOGP Europe.
IOGP Europe urges the European Commission to incorporate the following changes and calls on the European Parliament and the Council to object to the current version until the Commission amends the DA accordingly:
- Allow producers to use actual certified supplier or project-specific values for all upstream gases (CO2, CH4, N2O) alongside default values in Annex Part B for hydrogen produced via methane reforming with Carbon Capture and Storage.
- Recognize more options to use low-carbon intensity electricity for hydrogen production, including through PPAs.
- Provide for a grandfathering clause for projects that have taken FID, to ensure that the methodology and thresholds remain unchanged throughout the asset's lifetime. The methodology should not rely on yet-to-be-developed regulations (e.g., methane intensity methodology, third-country CCS equivalence)
- Ensure flexibility when demonstrating alignment with EU legislation for third countries on CO2 storage in third countries when CCS is used in the hydrogen production process, ensure flexibility when demonstrating alignment with the purpose of the CCS Directive.
- Ensure pragmatic criteria for hydrogen produced via methane pyrolysis, allowing this promising low-carbon technology to scale and deliver climate benefits as it matures.
- Ensure the methodology is practically workable from day one for importers by leveraging existing certification schemes beyond UDB, to enable the use of feedstocks and low-carbon fuels shipped across grids outside the EU.
Starting with a fit-for-purpose Delegated Act for Low-Carbon Hydrogen, and in line with the Clean Industrial Deal’s objectives, IOGP Europe strongly supports the European Court of Auditors’ call for a revision of the Hydrogen Strategy.
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