Position Paper

Industry publishes joint recommendations for Low-Carbon Fuels Certification

Eurogas has published a joint statement on the Low-Carbon Fuels Certification Delegated Act. The co-signatories of this letter welcome the intention of the European Commission to define the necessary elements for the certification of low-carbon fuels in order to support a clear regulatory framework, a prerequisite for their needed ramp-up.

In the context of the drafting of the Delegated Act, the co-signatories wish to express key recommendations regarding the guiding principles laid down in Articles 9 and 92 of the Hydrogen and Gas Directive.
These guiding principles must be implemented ensuring regulatory certainty and clarity for project developers, whose timelines extend beyond the already foreseen 2030 review of the Delegated Act.

The co-signatories:

  • Support the intention to deliver this Delegated Act efficiently and swiftly in order to establish a clear regulatory framework to support the ramp-up of low-carbon fuels, while making sure that accelerated drafting process does includes all production pathways.
  • Welcome the intention to apply equivalent requirements for domestic and imported low-carbon fuels to ensure a necessary level playing field.
  • Consider that the 70% GHG emissions threshold should be the sole benchmark for the low-carbon status. The co-signatories consider necessary to include in the Delegated Act the possibility to recognise and provide adequate proof of better performance of individual projects, at each step of the production process, compared to the default GHG emission values to be set in the Delegated Act. This will foster innovation and encourage overall emissions reduction. In that framework, any default values should be subject to review by the European Commission.
  • Guarantee that this certification process and demonstration of better performance should be simple and credible in providing certainty about the GHG credentials of the low-carbon fuels. It must help to standardise a market product that is credible, traceable, tradeable, easy to communicate and practicable.
  • Underline the need to ensure consistency with the requirements of the Methane Emissions Regulation and to leverage the improving data availability and granularity of its implementation.
  • Stress the importance of considering the technical maturity and availability of hydrogen leakage detection technologies, a prerequisite before their integration to the GHG emissions calculation of low-carbon fuels and RFNBO.
  • Welcome the intention to create a link with the RED Union Database and encourage the European Commission to ensure that the provisions defined for renewable gases are also applicable to low-carbon gases, specifically those related to the mass balancing of gaseous fuels as per the Renewable Energy Directive2 and its Implementing Act on rules to verify the sustainability and GHG emissions savings.

Read more in the full joint statement below.