Climate Policy Engagement Analysis
Climate Policy Engagement Overview: Hydrogen Europe appears to be actively engaged on European climate policy with some supportive and unsupportive positions, including the EU Renewable Energy Directive and the EU Energy Performance of Buildings Directive. The association also has some supportive and unsupportive positions on the energy transition with support for the increased use of renewable but also advocacy for hydrogen in multiple sectors, including non-hard-to-abate sectors such as heating and the role of hydrogen blending with fossil gas.
Top-line Messaging on Climate Policy: Hydrogen Europe’s top-line messaging on climate policy is positive. The association recognized the need for urgent action to combat climate change in a consultation response in June 2023 and in a press release from the CEO, Jorgo Chatzimarkakis, in July 2023. The association also strongly supporting the European Green Deal, advocating for it to be prioritized in the EU's Strategic Agenda and calling for a 'Clean Industrial Deal' to complement it in a joint statement in June 2024.
Engagement with Climate-Related Regulations: Hydrogen Europe is highly engaged on European climate-related regulations and appears to have a mixture of positive and negative positions.
Hydrogen Europe appears to hold negative positions on policy related to energy efficiency. For example, in a February 2023 consultation response, the association opposed any demand management measures in the reform of the EU Electricity Market Design which were included in the proposal to contribute towards reducing fossil gas-fired generation. In a September 2023 joint letter, Hydrogen Europe also appeared to advocate to weaken the EU Energy Performance of Buildings Directive, calling for the definition of zero-emission buildings to consider grid energy sources instead of additional renewable capacity.
The associations positions on renewable energy policies, specifically the EU’s Renewable Energy Directive (RED) includes broad support for the policy and its targets however Hydrogen Europe does not appear to support criteria for reaching these targets such as additionality. For example, Hydrogen Europe supported ambitious targets for Renewable Fuels of Non-Biological Origins (RFNBOs) in the transport sector within RED in a December 2022 Joint Letter to EU Energy and Transport Ministers and supported the final adoption of the policy in an open letter in June 2023. The associations CEO also supported the policy, through sector-specific renewable energy sub-targets in a press release in March 2023.
However, Hydrogen Europe appeared to advocate to weaken the Delegated Act on RFNBOs in the EU RED by advocating for it to delay the additionality principle application until 2028 and offer flexibilities to producers in a joint letter in October 2022. The CEO also did not appear to support the additionality principle and other criteria in a press release in February 2023 and an article in March 2023.
Hydrogen Europe holds a positive position on GHG emissions regulations. For example, in an April 2024 joint letter, the association supported the GHG emission reduction target of 55% by 2030 and broadly supported the adoption of the heavy-duty vehicle (HDV) CO2 standard. In a March 2023 press release, Hydrogen Europe also supported the European Parliament and Council agreement on the FuelEU Maritime legislation, including the GHG emission reduction targets.
Positioning on Energy Transition: Hydrogen Europe’s is supportive of the increased use of renewables and the removal of fossil fuel subsidies, however, it also appears to advocate for measures that weaken EU policies for the decarbonization of industry.
Hydrogen Europe is supportive of the increased use of renewables, the use of hydrogen to store renewable energy and the removal of fossil fuel subsidies. For example, the associations supported an increase in renewables and decrease in fossil gas in the European energy mix in comments submitted on the revision of the EU Electricity Market Design in February 2023. The associations CEO, Jorgo Chatzimarkakis, supported the use of hydrogen for renewable energy storage in a FOCUS Online article in August 2024 and supported the removal of fossil fuel subsidies in a interview with Energy Terminal in July 2024. Hydrogen Europe also supported the use of captured CO2 in fuels and products to replace virgin fossil carbon and supporting the use of renewables in a June 2023 consultation response.
However, Hydrogen Europe also appears to advocate for measures that weaken EU policies for the decarbonization of industry and advocates for the use of hydrogen in non-hard-to-abate sectors. For example, in June 2023 comments submitted on the EU Net Zero Industry Act, the association appeared to advocate for the inclusion of carbon capture and utilization in the list of strategic net-zero technologies and advocated for hydrogen to be used in light-duty transport. Hydrogen Europe also appeared to advocate for the use of hydrogen in non-hard-to-abate sectors, such as residential heating and "all" mobility applications and supported blending hydrogen with fossil gas on its corporate website accessed in September 2024.