Hydrogen Europe

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Climate Lobbying Overview: Hydrogen Europe appears to be actively engaged on European climate policy with mixed positions, including the EU ETS and CBAM. The association's position on the energy transition is also mixed, with continued support for all forms of hydrogen and the transitional role for fossil gas in the energy mix

Top-line Messaging on Climate Policy: Hydrogen Europe’s top-line messaging on climate policy is positive. The association is supportive of the EU’s Climate Law, which sets a climate neutral target for 2050, stating this in a January 2021 EU public consultation response, and in its charter accessed on its website in April 2021. Also within its charter, the organization appeared to support the Paris Agreement. The association also appears to state high-level support for the EU’s Fit for 55 climate legislative package in a December 2021 joint letter.

Engagement with Climate-Related Regulations: Hydrogen Europe appears to have mixed positions on climate-related regulations. The association’s position on the EU’s Carbon Border Adjustment Mechanism is supportive but reliant on major exceptions, for example in an October 2022 position paper, it called for the equal treatment of all forms of hydrogen in regard to carbon leakage protection. In a November 2021 consultation response, the association supported reforms to the ETS including an increase to Linear Reduction Factor, a one-off reduction of ETS cap, and a phase out of free allowances by 2027. Alongside this, the group supported the extension of the ETS to all hydrogen production technologies, and the creation of a new ETS scheme for the buildings and road transport sectors.

In an October 2022 press release, Hydrogen Europe supported stronger ambition in the FuelEU Maritime legislation, including not supporting exemptions for small companies. In a July 2021 position paper, Hydrogen supported higher long-term CO2 emissions standards for light-duty vehicles, but emphasized the need for 2025 targets to remain constant.

Hydrogen Europe’s support for the EU’s Renewable Energy Directive (RED) has also been mixed. The association supported higher ambition in the EU’s 2030 renewable energy target of at least 45% on social media in December 2021. However, Hydrogen Europe has consistently lobbied to weaken the EU’s RED draft Delegated Act on renewable fuels of non-biological origin (RFNBOs). In an October 2022 joint letter to EU policymakers, the association called for the inclusion of a grandfathering clause to delay strict guidelines for renewable hydrogen production until 2028. In a previous July 2021 LinkedIn post, Jorgo Chatzimarkakis appeared to advocate for the RED Delegated Act to not discriminate against fossil-based hydrogen. While in February 2022 Recharge News reported CEO Jorgo Chatzimarkakis did not support the implementation of the additionality principle, a requirement for renewable energy needed for green hydrogen production to be additional to renewable electricity, by suggesting it would harm renewable hydrogen production.

Positioning on Energy Transition: Hydrogen Europe’s position on the energy transition appears to be mixed. In a May 2022 position paper, the association supported reducing the dependence on fossil fuels and advocated for a greater role of hydrogen and low-carbon gases in the REPowerEU proposal. In June 2022 Hydrogen Europe signed a joint letter supporting a 6% 2030 EU e-fuels target for shipping, alongside targets for sustainable e-fuel hydrogen refueling infrastructure for shipping as part of the EU's Alternative Fuel Infrastructures Regulation. The association advocated for positive reforms in the revision of the EU’s Energy Taxation Directive, and supported a reduction in fossil fuel subsidies in its January 2021 public consultation response. The organization strongly supported the promotion of green hydrogen to decarbonize the transport and industrial sectors in a joint letter to EU policymakers in March 2021.

Hydrogen Europe also appears to support a transitional role for fossil gas in the energy mix, specifically in blending with hydrogen. In a February 2022 interview with CEEnergy, CEO Jorgo Chatzimarkakis appeared to support the EU’s Hydrogen and Gas Decarbonization Package, but advocated for all forms of clean hydrogen to be included, without specifying which production methods it includes. This could enable fossil fuel produced hydrogen to be supported in the policy. Hydrogen Europe also advocated the inclusion of fossil gas and hydrogen blending in a June 2022 position paper on the gas package. In a S&P Global article in April 2021, the association appeared to support a weakening of the EU Taxonomy, by advocating for the inclusion of non-renewable hydrogen through a higher emission threshold for low-carbon hydrogen.

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