Delivering Europe’s Hydrogen Ambitions: Joint Industry Roadmap Ahead of the First European Hydrogen Forum
We, the undersigned organisations, representing the entire hydrogen value chain in Europe, welcome the organisation of the first European Hydrogen Regulatory Forum. This constitutes a necessary platform to foster open and structured dialogue between policy makers, regulators, and industry representatives to address outstanding regulatory challenges. With the core legislative framework in force, this Forum offers the right setting to assess what delivers positive results, simplify what falls short, and ensure that the rules reflect real-world market conditions.
Over the past years, the European Union has positioned hydrogen and its derivatives as a central pillar of its climate, energy and industrial strategies1. However, despite the stated level of ambition, ramp up of the market have faced delays, underpinning the need for regulatory adjustments2. The current policy landscape relies on highly detailed and prescriptive rules, leaving limited room for flexibility in a still-nascent market. This lack of proportionality increases costs, constrains market uptake, and prevents the emergence of a viable business case for both renewable and low carbon hydrogen and its derivatives across the entire value chain.
Addressing the shortcomings of the regulatory framework now is essential to drive the hydrogen business case, unlock demand, and ensure hydrogen and its derivatives can deliver on their role in Europe’s decarbonisation, resilience and competitiveness objectives. We therefore see this Regulatory Forum as a timely opportunity to highlight these constraints and to engage in a constructive discussion on how to build an open and liquid market. The way forward should be structured around the following action points, each to be addressed with the same level of priority and in a coordinated manner:
Ramping up production: The rules governing hydrogen production and its derivatives, be it renewable or low carbon, are too rigid and complex. The current approach needs to be significantly simplified, to provide flexibility and ensure technology-neutrality, by linking support and eligibility based on verified lifecycle GHG intensity of the fuel.
Scaling up demand: The policy focus should be directed to efforts developing market-based frameworks that reward lower GHG-intensity products on the basis of lifecycle CO₂ emission performance standards.
Rolling out infrastructure: Hydrogen infrastructure is essential to Europe’s market scale-up. A phased cluster-based approach, aligned with the development of a future European backbone, should steer investment, complemented by blending, asset repurposing and the recognition of CO₂ infrastructure as strategic to the hydrogen value chain.
Strengthening financing and de-risking: Financing frameworks should provide support across the hydrogen value chain, addressing competitiveness gaps, de-risking infrastructure and enabling timely final investment decisions.
Facilitating imports to complement domestic production: The revised European Hydrogen Strategy should more comprehensively address the role of both renewable and low-carbon hydrogen imports and derivatives, clarifying viable mechanisms, potential infrastructure (including import corridors and bunkering) and strategic partnerships to support EU’s demand ambitions.
Download full PDF below.
