IOGP Europe recommendations on the Delegated Act specifying a methodology for assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen
Clear and consistent rules on assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen can help to ramp-up low-carbon hydrogen production, develop a European market for hydrogen and facilitate the integration of hydrogen from renewable sources.
IOGP Europe recommends that the methodology for assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen should:
• Reward (use of) low-carbon fuels and hydrogen for their GHG emissions savings on the basis of a life-cycle analysis. The methodology should enable and reward industry using low-carbon hydrogen as a pathway to decarbonization.
• Be consistent in the methodology to assess GHG emissions across all types of fuels.
The methodology to assess GHG emissions savings for low-carbon fuels and low-carbon hydrogen should be consistent with the methodology for biofuels laid down in Directive 2018/2001 (part C of Annex V and part B of Annex VI) and the methodology for renewable fuels of non-biological origin and recycled carbon fuels specified in Delegated Act 2023/1185.
• Recognize carbon capture and geological storage (CCS) to produce low-carbon fuels and lowcarbon hydrogen, including CCS outside of the EU.
CCS outside of the EU should be reflected in the methodology to enable import of low-carbon hydrogen as well as EU produced low-carbon hydrogen where the CO2 is stored in neighboring countries, provided that rules equivalent to Directive 2009/31/EC apply to those CO2 storages.
• Reward innovations that reduce carbon intensities in the natural gas supply chain versus the fixed carbon intensity values in the table in part B of the Annex to DA 2023/1185.
Actual carbon intensities over the whole supply chain should be used where natural gas supplies more than half of the energy to produce low-carbon hydrogen since this qualifies as an incorporated process. Where this is not the case, or when actual carbon intensities cannot be established in a qualified and certifiable manner, the carbon intensity values in the table B of the Annex to DA 2023/1185 shall be used.
• Provide investors certainty that the minimum GHG savings threshold established in the Gas Directive will continue to apply for the project lifetime.
For investors in low-carbon production technology it is important to have certainty that the minimum GHG savings threshold will remain stable once an investment decision is made. The provisionally agreed Recast Gas Directive includes a provision by which the minimum GHG saving threshold for low carbon fuels could be increased in future. The minimum GHG savings threshold to qualify for low-carbon fuels and low-carbon hydrogen should continue to apply during the project lifetime, for installations that were built under this methodology. Any changes of threshold should apply only to projects for which investments decisions are made after the adoption of the changed threshold.
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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

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 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: 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.

Letter: IOGP Europe recommendations on the Hydrogen and Decarbonized Gas Market Package

Letter: Industry views regarding the proposal to establish a permanent demand aggregation and joint purchasing mechanism through the Recast Gas Regulation

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

Letter: Open, inclusive, and pragmatic Green Deal Industrial Plan for Europe

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

Letter: Call for a technology-inclusive revision of the TEN-E Regulation

“Hydrogen for Europe” study launch

Towards greater hydrogen production capacity in Europe

Letter: IOGP input on the European Commission’s consultation on the priority list for the development of gas network codes and guidelines for 2021 (and beyond)

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

Letter: 57 industry leaders call for enhancing gas contribution to decarbonisation

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

Wide industry coalition call for a Hydrogen Strategy inclusive of all clean hydrogen pathways

Hydrogen for Europe: 1st Working Group Meeting

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
