European Commission's Draft Act on Low-Carbon Fuels: Stakeholders' Concerns and Recommendations
Key Ideas
  • Stakeholders, including producers and users of low-carbon hydrogen, express concerns about the EU's draft Delegated Act for low-carbon fuels certification potentially hindering hydrogen deployment.
  • Recommendations include recognizing better project performance, considering electricity GHG efficiency, supporting CCS and CCU with clarifications, addressing leakage detection, integrating with existing databases, ensuring regulatory stability, and streamlining accreditation processes.
  • The coalition emphasizes the need for a level playing field for domestic and imported low-carbon fuels, advocating for a technologically neutral approach to support the EU's net-zero emissions objectives.
  • Stakeholders propose ongoing collaboration and a stakeholder forum to shape effective policies for advancing low-carbon fuel technologies in Europe.
A coalition of stakeholders, representing project developers, producers, infrastructure operators, and market users of low-carbon fuels, has released a joint statement concerning the European Commission's draft Delegated Act for low-carbon fuels certification. The coalition, which includes advocates for low-carbon hydrogen and its derivatives meeting a minimum 70 per cent greenhouse gas (GHG) reduction threshold, views these fuels as essential for the EU's transition to net-zero emissions. However, the stakeholders have raised apprehensions that the current draft Act might impede the deployment of low-carbon hydrogen and potentially obstruct the EU's hydrogen goals. The stakeholders support the European Commission's objective of establishing a certification framework that ensures equality between domestic and imported low-carbon fuels. Nonetheless, they stress the necessity of a technologically neutral approach and propose various improvements to the Act: 1. Recognition of Better Project Performance: Advocating for recognizing projects achieving lower emissions than default values, with periodic reviews to promote continuous GHG reduction. They also seek flexibility for natural gas projects to demonstrate better GHG performance without restrictions. 2. Electricity GHG Performance Considerations: Highlighting the importance of low-carbon fuel producers demonstrating improved GHG efficiency for the electricity they consume, crucial for various processes like electrolysis and methane reforming. 3. Support for CCS and CCU with Key Clarifications: Urging clarity on third-country CCS recognition and the treatment of carbon storage and usage, including carbon products' longevity. 4. Addressing Technical Maturity in Leakage Detection: Emphasizing the need for mature hydrogen leakage detection technologies before mandating their inclusion in GHG calculations. 5. Integration with Existing RED Union Database: Supporting the linkage of low-carbon fuel traceability with the Renewable Energy Directive's (RED) Union Database for consistent treatment of renewable and low-carbon gases. 6. Regulatory Stability for Long-Term Projects: Advocating for stable regulations beyond the planned 2030 review to provide developers with predictability throughout project lifecycles. 7. Streamlining Accreditation for Voluntary Certification Schemes: Calling for an efficient process to accredit Voluntary Certification Schemes essential for ensuring reliable supply, trade, and demand. The coalition emphasizes ongoing collaboration and proposes a stakeholder forum to develop effective policies supporting low-carbon fuel technologies in Europe.
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