IOGP response to the inception impact assessment concerning the revision of the 2018 Renewable Energy Directive (REDII)

This document provides IOGP’s response to the inception impact assessment concerning the revision of the 2018 Renewable Energy Directive (REDII).

IOGP welcomes the European Commission’s plans to establish a comprehensive terminology for all renewable and low-carbon fuels and a European system of certification of such fuels, based notably on full life-cycle greenhouse gas emission savings and sustainability criteria.

On 8 July 2020, the Commission published the Communications ‘EU Strategy for Energy System Integration’ and ‘A hydrogen strategy for a climate neutral Europe’. These strategies propose several actions that could require the modification of REDII which are addressed in the Commission’s inception impact assessment concerning the Renewables Directive review.

Main recommendations:

• Ensure that renewable and low-carbon gases can fully contribute to the achievement of the EU climate ambition
• Establish a comprehensive terminology in a single legislative instrument that covers both renewable and low-carbon fuels
• Establish a robust certification system for renewable and low-carbon hydrogen by amending the provisions on Guarantees of Origin under REDII
• Include life-cycle GHG performance for all low carbon and renewable fuels into the Guarantees of Origin information
• Ensure a technology neutral approach in setting targets and providing support mechanisms
• Enable all hydrogen production technologies which can deliver significant GHG emission reductions to compete on a level playing field
• Provide regulatory predictability by avoiding that the possible changes to the Directive are disruptive to the long-term investment perspective provided under RED II