Position Paper

Eurogas’ guiding principles on low-carbon fuels.

Low-carbon fuels are defined in the Gas Directive (in its most recent version, yet to be formally approved) Art. 2 and include e.g. low-carbon hydrogen (and its derivatives), i.e. hydrogen produced from non-renewable energy sources and which meets a GHG emissions reduction threshold of 70%. This benchmark being calculated by using a fossil comparator referenced in the Delegated Act based on the Renewable Energy Directive Art. 29a (which is targeting transport fuels).

Associated to this threshold, the text defines multiple principles that should guide the drafting of the Delegated Act. In addition, Article 92 of the Gas Directive details the date of the review of the act and opens the possibility to introduce a new GHG emissions threshold for post-2031 installations.

Eurogas supports the intention to deliver this Delegated Act efficiently and swiftly in order to support the necessary ramp-up of low carbon hydrogen (-derivatives). In addition, we welcome the ambition of having a unified methodology for domestic and imported low-carbon, with an identical scope in terms of GHG emissions to be accounted. The establishment of a level playing field is an absolute necessity as hydrogen and its derivatives will be global commodities

Through this document, Eurogas details recommendations regarding low-carbon fuels certification for each of the principles detailed in the Articles 9 & 92 of the Gas Directive.