Getting hydrogen right from the start

June 24, 2022

T&E submission to Commission consultation on Renewable Fuels of Non-Biological Origin (RNFBOs)

T&E welcomes the technical work undertaken by the Commission in the preparation of these two delegated acts (DA), one on defining additionality and geographic and temporal correlation and the other one on a methodology to calculate the greenhouse gas savings of RFNBOs (and Recycled Carbon Fuels).

However, the major effort done to ensure that RFNBOs are produced with additional renewable energy is undermined by the insertion of a grandfathering clause in the DA setting out detailed rules for the production of RFNBOs. 

The exemption for electrolysers that come into operation before 2027 – especially in combination with the high RFNBO targets in the RED proposal and the further increase following RePowerEU – will cause a 500+ TWh of additional demand to produce around 10 million tonnes of green hydrogen in the EU. This is more than the electricity generated by all installed wind power in the EU27+UK in 2021.

It is regrettable that the Commission did not conduct an impact assessment on how adding such a significant load to European grids will increase emissions and impact electricity prices for electricity-intensive industries and all businesses and households more generally. As was the case for biofuels and its indirect land use impacts, ignoring the side-effects of non-additionality will undermine the credibility of RFNBOs as zero-emission fuels. 

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