Position Paper
23.06.2025

Joint statement: Urgent need for European Commission to correct course on the draft Delegated Regulation on Low Carbon Fuels

Download the full joint statement here.

Representing the entire energy value chain, from producers to industrial users, clean tech solution providers, and infrastructure operators, the co-signatories call on the European Commission to acknowledge their serious concerns with the current draft Delegated Act defining the GHG methodology for low carbon hydrogen and its derivatives, and to work with industry representatives on amendments.

The new version of this essential secondary legislation would make it overly difficult – if not practically impossible – to produce low carbon hydrogen and fuels, be it in the EU or at global level and imported to the EU.

This joint statement outlines the serious concerns about the current EU regulatory approach to hydrogen, which risks undermining the sector’s development. The co-signatories particularly underline the inability to fully showcase better GHG performance and the high default values. This detrimental approach is further exacerbated by several elements of concern e.g. the treatment of hydrogen from methane splitting, the implementation of provisions linked with the Methane Regulation, the recognition of CCS in third countries, and the inclusion of low carbon fuels in the Union Database.

These challenges, in addition to high costs and barriers, threaten the deployment of this essential energy vector, the overall uptake of hydrogen and its infrastructure for the EU, ultimately putting at jeopardy the Commission's own vision for low carbon hydrogen.

The co-signatories urge the European Commission to amend the revised draft to ensure it enables the production and import of all types of low carbon hydrogen and fuels and recognises better environmental performances. This is critical for supporting the scale up of the hydrogen market in Europe, which already faces major challenges that undermine EU’s ability to meet its climate objectives.

Download the full letter below.