The publication of detailed rules to define what constitutes renewable hydrogen in the EU, with the adoption of two delegated acts required under the Renewable Energy Directive, has been interpreted as a victory for France on the recognition of nuclear. It is not that simple though. So here are the source documents to make your own opinion.In an article published on Sunday, the Euractiv website announced that “France wins recognition for nuclear in EU’s green hydrogen rules.” As for the European Commission, it adopted a more neutral position in a press release published the following day. The first Delegated Act “defines under which conditions hydrogen, hydrogen-based fuels or other energy carriers can be considered as renewable fuels of non-biological origin (RFNBOs).” This clarifies “the principle of ‘additionality’ for hydrogen set out in the EU’s Renewable Energy Directive.” The second Delegated Act “provides a methodology for calculating life-cycle greenhouse gas emissions for RFNBOs. The methodology takes into account greenhouse gas emissions across the full lifecycle of the fuels, including upstream emissions, emissions associated with taking electricity from the grid, from processing, and those associated with transporting these fuels to the end-consumer.”
In a seperate press release, entitled “Questions and Answers on the EU Delegated Acts on Renewable Hydrogen” the Commission addresses the nuclear issue more clearly. As such, to the question “Is hydrogen produced from nuclear power considered ‘renewable’ under these delegated acts?” it answers: “The proposed delegated acts stem from the Renewable Energy Directive, under which nuclear is not listed among the renewable energy sources. As part of the Hydrogen and gas markets decarbonisation package proposed in December 2021 and currently being negotiated by the co-legislators, the Commission put forward a definition of low-carbon hydrogen, that is when it is derived from non-renewable sources and produces at least 70% less greenhouse gas emissions than fossil natural gas across its full lifecycle. Under the Commission’s proposal, a methodology for assessing greenhouse gas emissions savings from low carbon fuels will be set out in delegated legislation by 31 December 2024.”
France Hydrogène published a press release (this one is in French) yesterday welcoming the news as “a considerable step forward.” However, the association considered that “it would be wrong to consider it as an acknowledgement of the role of nuclear or electrolytic hydrogen as low-carbon.” It also stressed that, as it stands, “hydrogen produced by electrolysers connected to the French electricity grid that would be supplied by nuclear power (via a long-term contract, for example) instead of renewable PPAs*, could not be counted towards the renewable hydrogen use targets defined in RED3, nor could it be included in the scope of the Innovation Fund or in the announced scope of the European Hydrogen Bank.” For Philippe Boucly, President of France Hydrogène, “The story does not end here, we will perservere in our efforts to ensure that hydrogen produced from nuclear electricity is recognised in the achievement of the decarbonisation targets.”
As for the Euractiv website, it comes back to these famous Delegated Acts, with the headline “France calls for ‘coherence’ in sea of EU hydrogen rules.” These comments were made on Monday by the office of the French Minister for Energy, which was referring in particular to the Renewable Energy Directive (RED II) currently being negotiated by European legislators. According to the same source, “all other EU texts related to hydrogen should also take into account the conclusions of the last few days.” And Euractiv translates: “Other EU initiatives that need adaptation include the ReFuelEU regulation on aviation fuels, and memorandums of understanding (MoU) signed with EU partner countries, French sources say. Another is the upcoming EU Hydrogen Bank, which was announced by Commission President Ursula von der Leyen in September.”
According to this site, France is counting on the support of its neighbours, especially Germany and Spain, with whom it recently signed agreements to develop cross-border hydrogen transport infrastructures.
*Power Purchase Agreements
Article written by Laurent Meillaud and translated by Logan King
