Study

Certification of green and

low-carbon hydrogen
An overview of international and national initiatives
2

Impressum
Publisher:
Japanese-German Energy Partnership Team

Implementing Organization:
adelphi consult GmbH
Alt-Moabit 91
10559 Berlin
T +49 (30) 8900068-0
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office@adelphi.de
www.adelphi.de

Authors:
Roman Eric Sieler, adelphi
Henri Dörr, adelphi

Cite as:
Sieler, Roman Eric; Henri Dörr (2023): Certification of green and low-carbon hydrogen. An overview of international and national
initiatives. Berlin: adelphi.

Photo Credit:
© Shutterstock/petrmalinak
© Shutterstock/Audio und Werbung

Version:
03/2023

All rights reserved.

All use of this publication is subject to the approval of adelphi consult.

This publication is commissioned on behalf of the

Federal Ministry for Economic Affairs and Climate
Action. adelphi supports the Federal Government in
various projects to implement the energy and climate
policy goals within the framework of the energy
transition.
3

Certification of green and low-carbon hydrogen

An overview of international and national initiatives
4

Content
1 Executive Summary .......................................................................................................................................................................... 6

1.1 International Initiatives .................................................................................................................................................................................................................6

1.2 Asia ........................................................................................................................................................................................................................................................6
1.3 The Americas .....................................................................................................................................................................................................................................6
1.4 Europe ..................................................................................................................................................................................................................................................7
1.5 Conclusion ..........................................................................................................................................................................................................................................7

2 Introduction....................................................................................................................................................................................... 8

2.1 Hydrogen as an energy carrier ..................................................................................................................................................................................................8

2.2 Colors of hydrogen .........................................................................................................................................................................................................................8
2.3 The hydrogen value chain ...........................................................................................................................................................................................................9
2.4 The case for hydrogen certification .........................................................................................................................................................................................9
2.5 The focus of this study ..................................................................................................................................................................................................................9

3 International Initiatives ................................................................................................................................................................. 10

3.1 IPHE .................................................................................................................................................................................................................................................... 10

3.2 CEM – IEA ........................................................................................................................................................................................................................................ 10

4 Regional and national initiatives on hydrogen certification .................................................................................................... 12

4.1 Asia ..................................................................................................................................................................................................................................................... 12

4.2 The Americas .................................................................................................................................................................................................................................. 15
4.3 Europe ............................................................................................................................................................................................................................................... 18

5 Conclusion: Possible further steps and areas to address together. ......................................................................................... 21

5.1 Comparison..................................................................................................................................................................................................................................... 21
5.2 Recommendations and potential for cooperation ......................................................................................................................................................... 22

Publication bibliography ......................................................................................................................................................................... 23

5

Editorial

© Shutterstock/petrmalinak

Dear Reader,
As important as the establishment of an international market
is to decrease and level-out prices across the world, it can
In light of recent events, most importantly Russia’s war of only arise with solid foundations for trade, international
aggression against Ukraine, the world is increasingly looking standards being crucial in this regard. While some standards
for alternatives to fossil fuels. Moving away from fossil fuels only need to be agreed on based on technical
does not only offer strategic independence from individual considerations, aspects which are more political in nature
providers of such fuels, increasing security, it also offers a might require significantly more cooperation.
solution for another ongoing crisis: climate change. With
countries around the world setting themselves targets for The definition and certification of green and low-carbon
net-zero, new energy sources will be needed to decarbonize hydrogen is central in this political context, as the carbon
all sectors of our economies – including some industrial intensity of hydrogen differs greatly between production
sectors which have been hard to decarbonize so far. technologies. While production through electrolysis using
renewable electricity generates almost no emissions,
Green and low-carbon hydrogen promises to be the solution different alternatives such as gas-based hydrogen with CCS
to these challenges, which is why countries around the world emit varying levels of CO2. Considering the net-zero targets
are turning their attention towards the development of and the expected role hydrogen will play in the
policies and technologies to upscale the usage of hydrogen decarbonization of economies, this emission intensity could
and its derivatives. In this regard, one must be mindful of the significantly determine the ability of hydrogen to deliver on
challenges we are still facing regarding this scale-up. Even the net-zero goal and is therefore an important quality to be
though production technologies are evolving rapidly, the considered in trade. Moving quickly on this issue is vital to
opportunities and costs for hydrogen production differ enable investment in hydrogen production capacity,
widely between different countries. Therefore, international especially considering the implementation timelines of such
trade will be vital to the large-scale use of hydrogen in some projects.
of the world’s most advanced economies. This is especially
the case if we want to move past what some have labelled as The importance of hydrogen certification is underlined by
hydrogen being the “champagne” of the energy transition – the fact that several nations around the world work on
a scenario in which hydrogen would be so expensive and definitions and certification systems for hydrogen. The
scarce that it could only be used very selectively. following study will give an overview over the current state
of considerations in some of the world’s leading economies,
trying to identify similarities and differences between
approaches.
6

Korea recently became a forerunner regarding the

1 Executive establishment of global hydrogen trade through its Clean
Hydrogen Trade Initiative, which is intended to foster
Summary international discussions, including clean hydrogen
certification. Furthermore, a national certification system for
low-carbon hydrogen is currently under development and is
Green and low-carbon hydrogen are a crucial pillar planned to launch in 2024. It focuses on blue hydrogen, with
of decarbonization strategies around the world. a tentative certification threshold of 42gCO2eq/MJ.
Since many industrialized nations do not have the
China is currently the largest hydrogen producer in the world
conditions to produce enough hydrogen, global and is therefore of great importance to the future market.
trade will be a necessary enabler for large-scale While different government strategies clearly reference low-
hydrogen application. To ensure that traded carbon hydrogen and demonstration projects of green
hydrogen will contribute to decarbonization, clear hydrogen production are being launched, there is no
rules and standards as well as certification schemes mentioning of a national standard or certification system yet.
are required as the foundation for this emerging Private initiatives are however discussing the topic and the
hydrogen market. This study explored existing as China Hydrogen Alliance has already proposed a standard.
well as emerging regulations and initiatives in this
regard around the world. 1.3 The Americas

Both Canada and the United States are in the special

position of being expected to become both major users as
1.1 International Initiatives
well as producers of low-carbon hydrogen. Chile in South
America is already positioning itself as a leading future
On a global level, IPHE, the International Partnership for
exporter.
Hydrogen and Fuel Cells in the Economy, plays a central role
in the development of standards and methodologies to
While low-carbon hydrogen was not referenced in the US’
estimate the carbon footprint of hydrogen. Its Hydrogen
first hydrogen strategy published by the Trump
Production Analysis (H2PA) Task Force has already created a
administration, the Biden administration has quickly turned
draft methodology, which is the result of an open process
this perspective. After the Infrastructure Bill mandated the
joined by a selective group of countries and is seen as a first
development of a Clean Hydrogen Strategy and a Clean
step towards an international standard. Australia is already
Hydrogen Production Standard, drafts of both have been
working on a guarantee of origin system in line with the
published in September 2022. The strategy clearly underlines
mechanisms proposed by IPHE.
the importance of clean hydrogen in the US’ climate
strategy, while the Standard suggests a clear definition for
Furthermore, the Hydrogen Initiative of the Clean Energy
clean hydrogen, which is supposed to be the foundation of
Ministerial (CEM H2I) is cooperating with IPHE and seeks to
future funding decisions by the US Department of Energy.
provide a basis for the utilization and testing of IPHE-
Additionally, the newly passed Inflation Reduction Act (IRA)
developed standards.
is expected to speed up low-carbon, and in particular green
hydrogen production through the largest hydrogen
1.2 Asia subsidies worldwide, in the form of hydrogen production tax
credits (PTC). California, the forerunner regarding hydrogen
Leading Asian countries are at the forefront of the certification within the US, had already developed a
advancement of a global hydrogen economy, mostly monitoring and certification system for renewable hydrogen
through technological advancements in hydrogen utilization. in the context of its Low Carbon Fuel Standard, introduced in
Since Japan and Korea both target net zero emissions by 2007.
2050 and China by 2060, low-carbon hydrogen (referring to
all production methods with comparatively low CO2 The Canadian Hydrogen Strategy from 2020 suggests to
emissions, including green hydrogen produced from introduce technology-neutral thresholds for emissions of
renewables) is furthermore relevant regarding their climate low-carbon hydrogen and stresses the importance of
ambitions. designing a relevant methodology together with
international partners. In this regard, the Strategy clearly
Public records of meetings of Japan’s Hydrogen Policy references the EU’s CertifHy system as well as CertifHy’s
Subcommittee acknowledge the need for a reduction in CO2 threshold. Furthermore, Canada is closely cooperating with
emissions along the hydrogen value chain. The the US to develop and align standards.
establishment of a clear definition of clean hydrogen as well
as the introduction of a certification system have been Chile plays a special role as a prime example of a future
discussed, but are not being implemented at the moment. At exporting country. Its 2020 Hydrogen Strategy points
the same time, Aichi Prefecture has already established a towards the necessity of hydrogen certification and
regional certification system. emphasizes that Chile intends to promote the establishment
7

of international certification systems as a foundation for an the differences in ambition and focus, with countries like
export market. Germany or the US either targeting green hydrogen directly
or providing substantially higher support for green
1.4 Europe hydrogen, while others, like Korea, have a clear focus on blue
hydrogen produced from natural gas.
The European Union’s approach is standing out in so far as it
explicitly mentions goals for the production of renewable For the successful implementation of a global hydrogen
hydrogen, with low-carbon hydrogen using CCS only economy, a harmonized approach is, however, crucial to give
referenced as a bridge technology for the medium term. potential exporters a system to rely their investment
Certification and definition of criteria for renewable and low- decisions on, which is why leading hydrogen economies
carbon hydrogen are considered key for boosting demand should seek ways to implement globally harmonized, or at
for and scaling up production under the EU Hydrogen least globally applicable, certification solutions.
Strategy. A comprehensive European terminology and
certification standards have recently been published in
February 2023 in the form of two delegated acts by the
European Commission. These acts contain a detailed
methodology for the certification of renewable hydrogen. In
addition, the EU has already launched a voluntary hydrogen
certification system, CertifHy, which establishes emission
standards and has already been used to certify green and
low-carbon hydrogen.

Germany, as Europe’s most important actor regarding the

hydrogen economy, has decided to focus on green hydrogen
and only transitionally to include blue hydrogen to achieve
its net zero target. Nonetheless, government funding is
predominantly targeted at green hydrogen. . In this regard,
the German Ordinance on the implementation of the
Renewable Energy Act establishes a clear definition for green
hydrogen, with the additional provision that Germany will
follow the EU standards as soon as they have been agreed
on. German industry has also been among the trailblazers of
hydrogen certification, with both TÜV Süd as well as TÜV
Rheinland having created green hydrogen standards. These
standards are based on German and European regulations
and set to connect to CertifHy; but open for projects around
the world. First projects have already been certified.

1.5 Conclusion

Most leading hydrogen economies analyzed in this study

acknowledge the need for hydrogen certification and stress
its importance in the context of hydrogen’s role for
decarbonization. However, the type of certification, the
degree of implementation as well as the level of ambition
differs substantially between countries. Thresholds for
certification range from 28.2gCO2eq/MJ in the currently
discussed EU threshold, ca. 33gCO2eq/MJ for the US Draft
Standard, 36.4gCO2eq/MJ for the EU´s CertifHy voluntary
scheme to 41gCO2eq/MJ and ca. 42gCO2eq/MJ for the
suggestion of the China Hydrogen Alliance and the currently
discussed Korean certification threshold.

Individual trailblazers in each region push the

implementation of internationally recognizable certification
systems and seek to use them as a basis for additional policy
measures aimed at supporting a low-carbon hydrogen
economy. However, the harmonization of these approaches
on the international level remains a challenge, mostly due to
8

2.2 Colors of hydrogen

2 Introduction
The terminology around hydrogen is often unclear and
different countries and stakeholders use different terms,
including clean, low-carbon or green/blue hydrogen, with
Green and low-carbon hydrogen will play a crucial the first to terms often used in a very general sense, referring
role in the world’s future energy system. Its to hydrogen produced with comparatively low emissions. In
potential uses range from decarbonization of steel reality, however, it is crucial to take different production
and metallurgical industries over transportation technologies and related emission intensities of hydrogen
and shipping to energy production. The following into account, especially if hydrogen is to be used as a
introduction will provide a short overview over decarbonization tool.
these use cases, the challenge of hydrogen value
So far, almost all global hydrogen production is so-called
chains as well as different production forms of
grey hydrogen, meaning hydrogen produced through the
hydrogen.
conversion of fossil fuels, such as coal or natural gas without
the removal of the CO2 emissions produced. While widely
used in industrial application, hydrogen produced in this way
2.1 Hydrogen as an energy carrier tends to be very CO2-intensive due to the previously
mentioned conversion losses and holds therefore little to no
Hydrogen as an energy carrier has the crucial advantage of value when it comes to decarbonization.
being very flexible in its use cases. This allows it to be a
potential decarbonization option for many sectors. A second option is to use fossil fuels, ideally natural gas as it
is less emission intensive than coal, to produce hydrogen,
First of all, hydrogen made from fossil fuels is already used in but to capture most of the generated CO2 emissions and
various industries, e.g. in the chemical industry, and could be either sequester or use them in a way in which they are not
replaced by green and low-carbon hydrogen in the future. released into the atmosphere. This leads to so-called blue
Hydrogen could furthermore be used as a replacement for hydrogen, which is part of many countries’ hydrogen
natural gas in many use cases, e.g. in industrial applications, strategies. While this does not imply full decarbonization
heating, as a cooking fuel or for energy production. It could considering current technology, it can contribute to a
also replace other traditional fossil fuels in many energy- significant emission reduction.
intensive industrial applications and in transportation, where
hydrogen cars, trucks, buses and trains have long become The third option is to use renewable electricity to generate
technologically feasible. so-called green hydrogen through electrolysis. If renewable
sources are being used, this option does not emit any CO2
Green and low-carbon hydrogen can furthermore be used as during the production process and is therefore seen as the
a basis for hydrogen derivatives, such as ammonia, which is option with the strongest decarbonization potential.
for example used in agriculture, but is also discussed as a
potential fuel for shipping. It is also an essential step in the Lastly, there are some additional options, including for
production of so-called e-fuels, artificially created example turquoise hydrogen, which uses a chemical process
equivalents to traditional fossil fuels used in automotive to produce hydrogen from natural gas, during which carbon
transportation. is generated in solid form, making air capture of CO2
unnecessary. Another option is – depending on the source –
Lastly, green hydrogen could serve as an energy storage yellow or pink hydrogen, produced through electrolysis
solution for renewable energies and therefore help to using nuclear energy.
smooth electricity generation in grids with a high renewable
share. In times of low demand and high supply of renewable This study will mostly refer to green hydrogen and low-
electricity, hydrogen could be generated and converted back carbon hydrogen, the latter referring to all production
into electricity in case of low supply. technologies with lowered CO2 emissions, importantly blue
hydrogen. In some instances, the term clean hydrogen is
However, the production of every type of hydrogen used as a catch-all term for both green and low-carbon
necessarily leads to conversion losses. This inefficiency calls hydrogen, as this is the terminology chosen by some
some of the mentioned use-cases in question and forces countries discussed.
policymakers to precisely plan, which sectors are optimally
suited to be decarbonized using hydrogen and for which
sectors other alternatives, e.g. electrification might be better
suited.
9

2.3 The hydrogen value chain they do not have the certainty that they will be able to sell
their low-carbon and green hydrogen in the future.
The current energy and fuel market is global in nature,
mostly due to the fact that energy producers and 2.5 The focus of this study
industrialized heavy consumers of energy and fossil fuels are
in most cases not the same countries. This has led to a Due to the reasons laid out above, which underline the
strong international trade in fossil fuels and energy. importance of hydrogen certification, this study seeks to
provide an overview over current approaches regarding
The same is likely to happen in the case of hydrogen. Grey hydrogen certification in the countries considered to be
and blue hydrogen are dependent on fossil fuel resources, most relevant for the future hydrogen economy. By
which would potentially give producers of these fossil fuels a comparing the different paths countries are taking, the study
comparative advantage in its production. More importantly, hopes to foster discussions on the advancement of hydrogen
however, is the case of green hydrogen. Most of the heavy certification both nationally and internationally and to
energy consumers of today – North America, Europe and provide examples for mutual learning. This is then distilled
East Asia – have only limited access to renewable energy, a into concrete cooperation potentials or potential synergies
problem that is exaggerated by conversion losses in the for bilateral or multilateral collaboration on the topic.
production of hydrogen. Therefore, they will likely need to
import green hydrogen from countries with better access to
renewable sources, such as solar and wind power – for
example from North Africa with excellent conditions for solar
energy or the southern part of Latin America with ample
wind resources.

2.4 The case for hydrogen certification

One has to assume that current cost differences between

grey, blue and green hydrogen will – at least in some sense –
persist in the medium run, with hydrogen generally being
costlier the less emission its production incurs. Therefore,
producers will have an incentive to provide hydrogen with
higher emissions. At the same time, however, countries and
businesses seeking to use hydrogen for decarbonization will
likely favor hydrogen with low emissions – either low-carbon
or green hydrogen, depending on their national strategy.
According to standard economic theory, a lack of clear and
reliable information on the color and exact CO2-footprint of
hydrogen could in this case cause a race to the bottom.
Without a credible way to guarantee the low carbon
emissions associated with their product, producers of green
or blue hydrogen would be unable to pass on higher
production costs to buyers. This would crowd-out green and
blue hydrogen production, causing only grey hydrogen to be
provided by the market.

Due to the importance of green and low-carbon hydrogen

for decarbonization and the need for international trade, it
therefore becomes crucial to enable both buyers and sellers
to clearly communicate the CO2 emissions related to traded
hydrogen. This necessitates the creation of monitoring and
certification systems for hydrogen, which should ideally be
globally accepted and uniform to avoid transaction costs and
market distortions.

Such hydrogen certification is therefore fundamental to the

establishment of a low-carbon and green hydrogen market.
Moreover, its timely implementation is crucial, as
investments in production capacity must be undertaken
timely to ensure sufficient future production capacity.
Producers will be unlikely to undertake such investments if
10

expertise of the first movers would likely play a crucial role in

3 International its development.

Initiatives Concerning the details of the methodology proposed by

IPHE’s H2PA Task Force, a draft methodology presented in
the fall of 2021 (IPHE 2021) is of particular importance. The
Due to the importance of international trade with document in question is the result of a process open to all
hydrogen and its derivatives in the context of the IPHE members but “does not necessarily reflect the views of
individual IPHE member countries”. This is in particular
hydrogen economy, global efforts towards
relevant since the members of the core team designing and
certification are already being implemented by directing the paper were exclusively from Europe and
different multilateral groups and organizations. Australia, even though experts from other IPHE countries,
Even though national initiatives, which will be including Japan and Korea, also contributed. The paper is
covered in more detail in following chapters, are in furthermore “not a conclusion or direction of the IPHE”, but
some cases further developed than these merely intended as the first step in a longer process.
international approaches, they lack the general
applicability needed for an efficient global market. The draft methodology is nevertheless noteworthy, as it is
Therefore, IPHE and the IEA are crucial forums for the first suggestion by the mentioned Task Force. Its aim is
to develop a “methodology and analytical framework to
the further development of certification and the
determine the GHG emissions related to a unit of produced
establishment of a global hydrogen economy. hydrogen”. The methodology is built on a range of core
principles, namely the non-exclusion of any potential
primary energy source used, flexibility, transparency,
3.1 IPHE comparability as well as practicality. By developing a
methodological framework, it partly references existing ISO
IPHE, the International Partnership for Hydrogen and Fuel standards, notably ISO 14040, 14044 and 14067, which were
Cells in the Economy is an international organization also referenced by IPHE member countries, e.g. in the
dedicated to the facilitation of “the transition to clean and standards suggested by the China Hydrogen Alliance. While
efficient energy and mobility systems using hydrogen” (IPHE discussing the contents of the proposed methodology is
2022b). The inter-governmental partnership currently has 23 beyond the scope of this overview, it is important to mention
member countries, including the European Union, and that prior analysis has underlined that the methodology
works on a range of different hydrogen-related issues “could potentially be a first step towards the creation of an
through its working groups and task forces. IPHE views the international standard” (Piria et al. 2021) and would provide
measurement and tracking of the greenhouse gas footprint a solid basis regarding many points. Nonetheless, the
of hydrogen as well as an accepted guarantee of origin or analysis also points out that the methodology has some
certification scheme as a crucial component for future shortcomings, e.g. regarding the estimation of fugitive
international trade (IPHE 2022a). methane emissions or electricity sourced from the grid. This
leads to a misalignment with the approaches by more
IPHE also supports the creation of such standards. One of its ambitions IPHE members, in particular with the European
task forces, the Hydrogen Production Analysis (H2PA) Hydrogen Strategy and the EU Renewable Energy Directive.
Task Force, is “aiming to develop a mutually agreed
methodology framework to determine the greenhouse gas 3.2 CEM – IEA
emissions associated with hydrogen produced from different
pathways” (IPHE 2022a), which seeks to build the
Different national governments cooperate on hydrogen in
foundation for a future international standard.
the framework of the International Energy Agency’s Clean
Energy Ministerial. The Hydrogen Initiative of the Clean
This is already bearing fruit, as Australia is currently working
Energy Ministerial (CEM H2I) is a voluntary initiative of
on a guarantee of origin (GO) scheme in line with the
several governments which mainly aims to advance
mechanisms proposed by IPHE. Moreover, IPHE suggests
hydrogen policy and projects. It is based on non-binding
that the bottom-up creation of a certification system could
agreements between the individual national ministries (IEA
be more efficient than creation via a top-down global
2022). A special activity on Hydrogen Certification began
system. A bottom-up approach would allow for the
under the 2021-2022 work program of the CEM H2I. This
emergence of different national initiatives and smaller bi- or
activity is being implemented together with the IPHE (see
trilateral groups that could later be consolidated. These
above), namely with the aforementioned IPHE Task Force.
groups could, driven by the ambition of individual
The idea behind this activity of the CEM H2I is to ultimately
trailblazers, move forward faster than top-down global
provide a basis for utilization and testing of the
approaches and later build the foundation for a global
methodologies developed by the IPHE Task Force.
system. Extending this idea, also means that such national or
Importantly, the EU, which chaired the H2PA Task Force at
bi-/tri-lateral initiatives could give individual countries more
the time of writing of the work program, will actively and
influence on a future global standard, as the experience and
regularly report to the H2I advisory group on the progress
11

made in the Task Force. H2I will then explore relevant

activities and opportunities (Clean Energy Ministerial and
Hydrogen Initiative 2020). CEM H2I does not work on
certification strategies or campaigns beyond this
cooperation with IPHE.

© Shutterstock/Audio und Werbung

12

a comprehensive hydrogen strategy is still outstanding at the

4 Regional and time of writing (Nakano 2022). These projects notably
include demonstration projects for the generation of green
national hydrogen from wind and solar power (National Development
and Reform Commission of the People's Republic of China

initiatives on 2022).

At the same time, however, almost all of the hydrogen

hydrogen produced in China as of now is produced from fossil

sources, with less than 1% being produced from renewable
sources (Song 2022). In light of the developing climate crisis
certification as well as China’s goal to become carbon neutral by 2060,
the generation of green and low-carbon hydrogen as well as
their certification is a pressing issue for China. This is
indicated by the growing political pressure from the China
An internationally standardized methodology Hydrogen Alliance, a private organization, which has been
would be the most effective approach towards calling for 100GW of electrolyzer capacity by 2030 (Nakano
certification in the long run. In the meantime, a 2022).
range of leading hydrogen economies have
It is, however, also reflected in official government
understood the need to move faster to securely
documents, most notably in the Medium and Long-term
and timely establish supply chains to power their
Plan for the Development of Hydrogen Energy Industry
industries and to reach their net zero targets in (2021-2035). In this document, the Chinese government
time. Understanding and comparing different emphasizes that “hydrogen energy is an important part of
national approaches offers the opportunity to the future national energy system” and that there shall be a
identify overlaps and potential areas for “focus on developing hydrogen production from
cooperation. Drawing on the nationally or renewable energy”.
regionally developed ideas can also benefit the
bottom-up development of a global standard as It also outlines goals to actively decarbonize different
industries and to establish a policy environment for the
pointed out in Chapter 3.
development of the hydrogen energy industry. Despite these
formulations and the goal to establish standards for the
quality and safety of hydrogen production, standards for
4.1 Asia green or clean hydrogen are not explicitly mentioned. The
document only stipulates that China aims to “actively
Asia is home to some of the world’s most advanced participate in international hydrogen energy standardization
hydrogen economies, in particular China, Japan and the activities”, without clarifying the underlying intention.
Republic of Korea. In terms of their approach towards
hydrogen, they share a focus on hydrogen application Despite the lack of a national standard or publicly
across different industries and a crucial role of hydrogen communicated efforts to implement its own national
in their strategies towards Net Zero. This also means that approach towards hydrogen certification beyond the
especially Japan and Korea are likely to become major participation in international fora, private actors have been
importers of hydrogen in the future, which underlines pursuing initiatives related to hydrogen certification.
the importance of international trade and certification. Especially worth noting is the ‘Standard and Evaluation of
Regarding certification, there are, significant differences Low-Carbon Hydrogen, Clean Hydrogen and Renewable
between different countries, which will be explored in Hydrogen’ which was issued in December 2020 by the China
more detail. Hydrogen Alliance. These guidelines propose specific
thresholds for two types of low-carbon hydrogen, so-called
4.1.1 China “low-carbon” and “clean hydrogen” as well as a more
detailed set of standards regarding accounting. In the
China, much like the other countries that will be discussed in
document, low-carbon hydrogen is defined as hydrogen with
this report, is also expected to play a major role in the future
greenhouse gas emissions below 14.51 kg CO2e/kgH2. Clean
global hydrogen economy. This is underlined by the size of
hydrogen is defined as hydrogen below emissions of 4.90kg
China’s economy and therefore its role as a leading producer
CO2e/kg (ca. 41gCO2eq/MJ, assuming 120 MJ/kg) (Liu et al.
and consumer of hydrogen. As of the time of writing, the
2021).
People’s Republic is the largest grey hydrogen producer in
the world and the country with the highest installed
4.1.2 Japan
renewable power generation capacity (Nakano 2022).
China has also been actively supporting the usage of Japan is at the technological forefront of the
hydrogen, e.g. in the mobility sector, and has started a range development of a global hydrogen economy, with a
of hydrogen-related projects even though the publication of particular focus on the use of hydrogen in industry,
13

electricity production and mobility. Importantly, hydrogen under a range of different initiatives or serve as voluntary
will also play a central role in Japan’s transition to net zero offsets, can also be used for hydrogen projects. Through this
by 2050, as outlined in its 6th Strategic Energy Plan (Agency system, green electricity used for green hydrogen production
for Natural Resources and Energy 2021). The importance of can be used to generate credits. METI has also announced
low-carbon hydrogen also underlined by the revised version that it plans to add hydrogen usage directly to the J-
of the Strategic Roadmap for Hydrogen and Fuel Cells from Credit system (Energy Conversation Center Japan and Asia
2019, which mentions the need for CO2 emission Energy Efficiency and Conservation Collaboration Center
reduction along the whole hydrogen supply chain. As of 2021). Specific details have not been confirmed yet.
now, Japan is pursuing a broad approach, with hydrogen
produced with low emissions generally being referred to as On the multilateral level, Japan is a member of the
clean hydrogen, irrespective of the production technology. International Partnership for Hydrogen and Fuel Cells in the
Therefore, Japan’s approach to clean hydrogen includes Economy (IPHE) described above, specifically in the H2PA
hydrogen produced from fossil sources with CCS as well as Taskforce. As initiator of the Hydrogen Energy Ministerial
hydrogen produced through electrolysis using renewable Meeting in 2018, Japan furthermore advocated for
electricity. international cooperation on technologies and the
harmonization of regulation, codes and standards in order to
Japan is discussing both the establishment of a precise speed up cost reductions for hydrogen supply and products
definition of clean hydrogen as well as the introduction of (Hydrogen Energy Ministerial Meeting 2021).
a certification and monitoring system. Even though no
details are known with regards to the current state of these 4.1.3 Republic of Korea
discussions, public records of meetings of Japan’s Hydrogen
Korea is also one of the leading actors when it comes to
Policy Subcommittee show that the Japanese Ministry of
the realization of a hydrogen economy, with a particular
Economy, Trade and Industry (METI) is aware of the need for
focus on the usage of hydrogen in the mobility sector. While
such a system, in particular in the context of international
Korea’s focus in the past was primarily on usage rather than
value chains (Ministry of Economy, Trade and Industry Japan
on clean production and procurement of hydrogen, this has
2022).
significantly changed over the last years. Already in
Korea’s 2020 Hydrogen Strategy (Park 2019), water
An important role is also played by the Council for a
electrolysis is mentioned as a central pillar of hydrogen
Strategy for Hydrogen and Fuel Cells (CSHFC) (Wenger
production and a 70% share of CO2-free hydrogen by 2040
and Wagner 2021). The council was founded by METI and
is targeted (Kan 2022), while first imports of clean hydrogen
consists of a range of industry stakeholders in the hydrogen
are aimed at for 2030. These are then expected to raise to 23
economy. In a 2017 report, the Council highlighted the
mio. Mt/year by 2050 (Lee 2021).
need for low-carbon hydrogen certification, and a
working group also proposed a system of four categories,
In particular to support the imports of hydrogen, the Korean
with the lowest tier being equal to 1.0-3.5 kg-CO2/Nm3-H2
government has introduced the Clean Hydrogen Trade
(ca. 324gCO2eq/MJ) and the highest 0.1-0.4 kg-CO2/Nm3-
Initiative in 2021, through which it intends to discuss and
H2 (ca. 37gCO2eq/MJ). This clearly underlines a demand for
further develop the foundations for global hydrogen trade
a certification system from the side of industry stakeholders.
with like-minded countries. The first of the cooperation areas
under the initiative is clean hydrogen certification, which
In addition, the Japan Hydrogen Association has recently
includes a standard to calculate life-cycle CO2 emissions as
published a proposed definition of low-carbon hydrogen
well as verification and mutual recognition of certification
reflective of a 70% reduction compared to natural gas steam
(Korea Pavilion 11/1/2021).
reforming. This definition suggests a threshold of 3.4
kgCO2eq/kg (ca. 28.3 gCO2eq/MJ) using a well-to-gate
In November 2022, the Korean administration announced
approach. The association also targets 3 million tons of clean
the new hydrogen economy policy of the Yoon government,
hydrogen produced by 2030 (Ministry of Economy, Trade
elected in February 2022, with a focus on “establishing a
and Industry Japan 2/27/2023).
clean hydrogen supply chain and nurturing a world-leading
hydrogen industry” (Ministry of Trade, Industry and Energy
At the same time, a regional certification system for low-
Korea 2022). Alongside building up a clean hydrogen
carbon hydrogen was launched by Aichi Prefecture in April
ecosystem domestically and globally, fostering technological
2018. The system focuses on direct emissions during the
innovation in Korea, building the necessary infrastructure,
production process, with hydrogen produced from
the introduction of a clean hydrogen certification system
electrolysis using renewable energy, hydrogen originating
remains a priority of the Yoon administration. Work on this
from the steam reforming of biogas or sodium hydroxide by-
national certification system for clean (low carbon)
product hydrogen being eligible for the system (Wenger and
hydrogen had started under the previous administration in
Wagner 2021).
2021 and is planned to be finalized in 2024 (IPHE 2022c). The
system is intended to include different production methods,
Apart from this regional approach, the J-Credit System,
ranging from green hydrogen production using electrolysis
under which third-party certified emission reductions can be
to blue hydrogen production using CCS. The Korean
traded and used to fulfil emission reduction obligations
14

government recently reaffirmed to also consider hydrogen The amendments include a definition of clean hydrogen, the
production from nuclear energy (Ha-Nee 2022). A draft of establishment of the aforementioned certification system as
the system, which will take international trends into account well as the requirement for hydrogen suppliers to supply
and is meant to also be used internationally, is expected for clean hydrogen (Son et al. 2022). Specifically, the new law
2023. defines clean hydrogen as including both CO2-neutral as
well as low-CO2 hydrogen according to standards set by
While discussions are still ongoing, as of December 2022, a presidential decree (Korean Ministry of Government
threshold of ca. 5kgCO2eq/kgH2 has been proposed based Legislation 2022). It tasks the Ministry for Trade, Industry and
on the current CO2 intensity of domestic blue hydrogen with Energy (MOTIE) with setting up a certification system
95% sequestration. It is foreseen that this threshold will be according to the provisions set by the aforementioned
gradually lowered. So far, only CCS, not CCU, is considered decree (Korean Ministry of Government Legislation 2022). It
for the certification of low-carbon hydrogen. The accounting also specifies that the Ministry has the power to certify
procedure focuses on “well-to-gate”, emissions up to and hydrogen and revoke certifications obtained under illegal
including production, for domestic and “well-to-import circumstances. Furthermore, the law specifies that MOTIE is
port”, furthermore including emissions from the transport to allowed to fund and administratively support producers
Korea via shipping, for imported hydrogen (Lee 12/6/2022). of certified clean hydrogen and to differentiate this
support according to the quality of the certification. The
An amendment of the Hydrogen Act to introduce Clean establishment of certification institutions as well as reporting
Hydrogen Energy Portfolio Standards was passed by the requirements for clean hydrogen producers are also
legislature in June 2022 and entered into force on the 12th mentioned. Lastly, the amended law also provides the
of November 2022. The Standards will require state utilities foundation for clean hydrogen requirements as well as for a
to purchase a fixed share of hydrogen as part of their overall trading market for electricity produced from hydrogen.
fuel procurement (Eun-Joo 2020). This will remove hydrogen
energy production from Korea’s existing Renewable Portfolio Through the establishment of a legal basis for the future
Standards (Song 2022). These require large energy producers implementation of a clean hydrogen certification system,
to use a certain share of renewable energy or to buy Korea leads the way in terms of hydrogen certification in
certificates from producers with higher renewable shares. Asia. Together with its ambition to cooperate with other
Before the introduction of the new standards, this system nations through the Clean Hydrogen Trade Initiative, it can
also supported hydrogen fuel cells by treating them as be assumed that Korea will become a major player in the
renewable energy sources without accounting for the variety context of global certification approaches in the future, with
of different hydrogen production methods. To support the a strong focus on blue, not green, hydrogen.
new Portfolio Standards, a bidding market to supply and
purchase hydrogen-generated electricity will also be
established in the first half of 2023 (Lee 12/6/2022).

© Shutterstock/petrmalinak
15

4.2 The Americas 14 gCO2e/MJ in 2030 (Government of Canada 2022). As in

California, there will be the option to generate tradeable
certificates, for example by providing low-carbon hydrogen.
While hydrogen will also play a crucial role for both
The standard will enter into force in July of 2023 (Scherer
decarbonization and the achievement of Net Zero goals
and Nickel 2022).
in the two leading industrialized nations in America,
Canada and the United States, the Americas differ from
Furthermore, Quebec aims to establish itself as a center for
the Asian nations discussed before. Several American
the production of green hydrogen. The province has
nations are expected to become major exporters of
developed its own Hydrogen Strategy, in which it stresses
green and low-carbon hydrogen due to the abundance
the importance of the certification of green hydrogen as well
of natural resources. This implies that certification is of a
as the harmonization of regulation with the US
two-fold importance for American countries. It matters
(Gouvernement du Québec 2022).
with respect to the decarbonization of their own
economies, but also as a foundation for the
There have also been important developments in the private
establishment of hydrogen exporting industries, like in
sector, most notably the foundation of CertifHy Canada,
the case of Chile or Canada. The latter two countries
which seeks to offer a private-sector solution to the
show that exporters are greatly concerned with the
certification of different types of low-carbon hydrogen
establishment of hydrogen certification, as they see it as
(CertifHy Canada 2021).
the very foundation of the future market.
With regards to international cooperation, it is important to
4.2.1 Canada
mention the Canada/US Regulatory Cooperation Council,
Canada is expected to play a major role as a future through which the two countries seek to develop and align
exporter of hydrogen, as formulated in its Hydrogen standards. Part of these efforts is also the development of a
Strategy, which was developed by the government in common methodology to determine the carbon intensity of
cooperation with various stakeholders in 2020 (Government different methods of hydrogen production (Government of
of Canada 2020). At the same time, Canada aims to achieve Canada 2020).
climate neutrality by 2050, which underlines the importance
of low-carbon hydrogen production for the Canadian case. 4.2.2 Chile
Chile is expected to play a role as a major prospective
As of now, Canada has yet to establish a clear definition of
exporter of hydrogen and proves that not only the demand
low-carbon hydrogen or targeted CO2 emission intensities
side of a future global market is actively working on visions
of hydrogen production, while the targeted percentage of
for the future. Producers of hydrogen might even be more
emissions reduced through CCUS is still debated (Teichmann
aware of the need for certification.
et al. 2021). This is especially relevant as Canada foresees a
significant role for blue and grey hydrogen. For both, the
Chile offers abundant natural resources, both wind in the
Canadian Hydrogen Strategy sets the ambition that fossil-
south and sun in the north, to facilitate the production of
fuel-based hydrogen production will “predominantly
green hydrogen and its derivatives. In order to take
[sequester a share] greater than 90 %” of CO2 by 2030. The
advantage of these resources for the future green hydrogen
strategy, however, does not provide a clear perspective to
market, Chile aimed at establishing itself as a green
zero emissions.
hydrogen provider early on. In 2020, the country published
its hydrogen strategy, which underlines Chiles advantages
At the same time, Canada is aware of the need for
for developing a hydrogen economy. The strategy also
certification and monitoring, especially in the context of
points towards the necessity of hydrogen certification and
potential exports. The Canadian Hydrogen Strategy suggests
emphasizes that Chile intends to promote the establishment
to introduce technology-neutral thresholds for emissions,
of international certification systems as a foundation for an
which can be independently certified. It also emphasizes the
export market (Government of Chile 2020).
importance of designing a relevant methodology in this
regard together with international partners. The strategy
This need for a certification system is also expressed by
furthermore explicitly refers to the EU’s CertifHy system as
potential exporting firms in Chile. A recent study (Boyle et al.
well as CertifHy’s threshold, namely 36.4 gCO2-eq/MJ. This,
2021) underlines that potential exporters need a clear
however, would not distinguish between different
certification scheme to initiate first projects and
production methods, some of which are significantly more
undertake the necessary investments. Only such a clear
carbon intensive than others.
scheme, either internationally or in bilateral cooperation with
an importer, would ensure that their products will have a
Similar to the Californian approach, which is discussed in the
market once the projects have been completed.
US chapter, Canada has also decided to implement a Clean
Fuel Standard, which will obligate primary suppliers of fossil
In addition, it was highlighted that the establishment is an
fuels to gradually reduce the lifecycle carbon intensity of
important issue, as large hydrogen production projects need
sold fuels. The carbon intensity reduction requirement will be
years to be implemented. If producers do not have a clear
gradually increased, starting at 3.5 gCO2e/MJ and reaching
16

framework to refer to in the very near future, it seems specifying any limits on CO2 emissions. This is most likely
unlikely that there will be the needed supply capacity driven by the political ideology of the last administration.
towards the end of the decade. The forthcoming strategy formulated by the Biden
administration includes major changes in this regard and
Additionally, a report prepared for the Chilean government puts a strong emphasis on green and low-carbon hydrogen.
and the World Bank cites the Chilean Hydrogen Association
in saying that the focus should be on certification rather Beyond certification, it is relevant to mention a number of
than labeling, to ensure verifiability, and that the market – relevant US’ initiatives towards the establishment of clean
the importers – would need to set the rules (Hinicio and hydrogen production, such as the Hydrogen Energy
Ludwig-Bölkow-Systemtechnik 2021), which is why Earthshot initiative (GenH2 2022), which is aimed at reducing
producers depend on the initiative from the importer’s side. the costs of green hydrogen by 80 % until 2030. In the
The same report also recommends Chile to follow the EU’s context of this initiative, the DoE mentions its goal to “lower
CertifHy standard in its own approach to certification, which life-cycle greenhouse gas emissions by at least 90% from
underlines the EU’s role as a trailblazer in this regard. current levels” for the production of hydrogen (Arjona and
Satyapal 2021). Other examples include various initiatives
4.2.3 United States under the Infrastructure Investment and Jobs Act, such as
the Hydrogen Hubs Implementation Strategy or the Clean
The Biden administration is targeting climate neutrality by
Hydrogen Manufacturing Initiative. The former was already
2050 (Kerry and McCarthy 2021). In this context, hydrogen
announced by the DoE in September 2022, with an overall
is of high relevance. Currently, the US is the second largest
budget of 7 billion USD, with concept papers being due in
producer and consumer of (grey) hydrogen in the world
November, which underlines the urgency with which the DoE
(Wood 2022). 99% of US hydrogen production is currently
pushes progress in this area.
based on fossil fuels, predominantly natural gas, with only
1% being produced through electrolysis. About 96% of
The newly passed Inflation Reduction Act (IRA) from
hydrogen consumed in the US serves as a feedstock or
August 2022 is expected to further speed up low-carbon,
reactant in petroleum refineries (57%), ammonia and
and in particular green hydrogen production and usage in
methanol (38%) and metals production (2%) (Sönnichsen
the USA. It is considered to include the largest hydrogen
2022).
subsidies worldwide, especially through hydrogen
production tax credits (PTC). Hydrogen with a minimum
The Infrastructure Bill passed by the Congress in early
reduction of 60 % GHG compared to unabated grey
November 2021 mandates the Department of Energy (DoE)
hydrogen (under 4kgCO2eq/kgH2) is eligible for the PTC.
to develop a National Clean Hydrogen Strategy and
The credit increases the higher the GHG emission
Roadmap and a Clean Hydrogen Standard, based on a
reductions, while only hydrogen under 0.45 kgCO2eq/kgH2,
GHG intensity standard for clean hydrogen of max. 2 kg
which will likely only hold for green hydrogen, qualifies for
CO2eq per kg of hydrogen at the production site. This
the top $3/kg tax credit. Blue hydrogen will also be eligible
definition excludes indirect upstream emissions and
for receiving the PTC, but only if it has not already received
downstream transportation emissions (U.S. Congress 2021).
tax credits for carbon capture, in order to further prevent
market distortions. Projections assume that with the PTC,
The draft of the Strategy was unveiled in September 2022. It
green hydrogen could become already price competitive
includes a range of provisions regarding the certification of
in the USA within this decade (Natural Resources Defense
hydrogen, for instance by proposing that best practices
Council 2022).
should be collected between 2022 and 2025 in order to
inform future guarantees of origin and certification schemes.
Closely related to the discussions around PTC is the
More importantly, the strategy lists the establishment of
discussion of a definition for “clean hydrogen” as a basis for
internationally accepted standards and certification
funding decisions by the DoE. Originally, discussions
schemes across the hydrogen value chain as a priority, with
followed the provisions in the Infrastructure Bill, namely 2 kg
a clear focus to connect already existing initiatives. It
of CO2 per kg of hydrogen. Since the definition in the
furthermore states that these would be “essential enablers”
Infrastructure bill is however limited to emissions at the
(U.S. Department of Energy 2022) of production and trade of
source, the DoE needed to find a different standard if it
hydrogen.
wanted to include up- and downstream emissions as well.
Following such considerations, the DoE published a Draft
As the new Strategy is only a draft as of now, the most
Clean Hydrogen Production Standard for feedback in
recent fully approved document is a hydrogen strategy
September of 2022, which sets an emission intensity target
formulated under the Trump administration in 2020 (U.S.
of 4 kg of CO2 equivalent per kg of hydrogen (ca.
Department of Energy 2020), which does not mention the
33gCO2eq/MJ, based on 120MJ/kg), thereby assuming 2 kg
establishment of green or low-carbon hydrogen certification,
CO2eq of direct emissions – following the Infrastructure Bill –
only referring to safety and technical standards. The strategy
and 2 kg CO2eq as indirect lifecycle emissions. For now, this
argues that the production of hydrogen with fossil fuels and
value is intended as a guidance for the DoE’s funding
CCUS would be the most cost-effective solution going
decisions.
forward, a claim that is questioned by the literature, without
17

Apart from federal government initiatives, there also exists a

“Roadmap to a US Hydrogen Economy” (Fuel Cell and
Hydrogen Energy Association 2020), formulated by different
industry stakeholders through the Fuel Cell & Hydrogen
Energy Association (FCHEA). It describes an ideal hydrogen
economy development scenario for the US. The roadmap
stresses the importance of certification and
“standardization of hydrogen practices to enable
broader deployment”, especially in the long term, as a
foundation for an effective clean hydrogen economy beyond
2030. It also points out that harmonizing definitions of the
hydrogen production pathway would be crucial for
regulation in the US as well as for exports. It continues by
providing examples for such pathway definitions, specifically
naming the EU’s definition of green hydrogen as well as the
European Certification System CertifHy as examples (see the
EU section of this paper). It also mentions Californian
standards on minimum renewable content for hydrogen
production for publicly funded fueling stations and
production facilities.

This points towards the special case of California. California

was one of the front-runners in the establishment of clear
definitions for green hydrogen in the context of the
adoption of its Low Carbon Fuel Standard (LCFS) in 2007.
This system sets an emission target for the mobility sector,
specifically for oil refineries and distributors, and establishes
a system of tradeable LCFS certificates. These certificates can
be used by entities with emissions exceeding the threshold
to offset their emissions and comply with the LCFS. These
certificates can be generated by users or distributers of low-
carbon fuels, such as clean hydrogen. In order to facilitate
this generation of credits, the system established a
certification and monitoring system for renewable
hydrogen used in vehicles or in fuel production. According
to the regulation, hydrogen refueling stations need to offer
at least a 33 % share of hydrogen from electrolysis,
biomethane or thermochemical conversion of biomass
(Achtelik 11/16/2009).
18

4.3 Europe should not lead to stranded assets” (European Commission

2020).
To reach its ambitious Net Zero targets, nations across
Europe will need to import large quantities of green and In response to the Russian invasion of Ukraine the European
low-carbon hydrogen from partners across the world. Commission (EC) passed the REPowerEU plan to diversify its
With some of these projects already being initiated, e.g. energy supply and accelerate the roll-out of renewable
between Germany and Canada, the issue of hydrogen energy, cutting the dependency on fossil fuel imports. The
certification is pressing. This likely also explains why plan sets the ambitious goals of producing domestically 10
Europe has moved much faster than most other regions million tons of green hydrogen and also import the same
on the establishment of hydrogen certification and amount by 2030 (European Commission 2022a). With these
already has a range of national and EU-wide certification ambitious targets, the EU settles its position to become one
initiatives established. While the situation is somewhat of the key players on the global hydrogen market, but will
like the one in leading Eastern Asian hydrogen have to import large quantities of green hydrogen (Taylor
economies, joint policymaking through the European 2022).
Union means both a stronger need for successful
international collaboration as well as a larger global To push the market towards the provision of the desired
impact of Europe’s decisions on hydrogen certification. quality and quantity of green hydrogen and its derivatives, a
demand side-supportive framework was installed by the
4.3.1 European Union EU. It is applicable to domestic and imported production to
create certainty for industry and investors for the needed
The “European Green Deal” is the climate policy flagship of long-term investments and build-up of a European, but
the European Union. It was passed in 2019 with the objective also global green hydrogen supply chain for export nations.
to achieve climate neutrality by 2050 within the EU. Clean The certification and definition of a set of criteria for green
hydrogen is listed among many other aspects as a key and low-carbon hydrogen were considered key actions for
priority contributing to this target (European Commission “boosting demand for and scaling up production” under the
2019). The harmonization of safety and environmental hydrogen strategy, giving security to market players.
standards is of critical importance to support the EU´s (European Commission 2022b). Therefore, it was decided to
efforts for global leadership in the clean energy put in place “a comprehensive terminology and European-
transition and will shape the development of the hydrogen wide criteria for the certification of renewable and low-
market for all players involved (European Union 2021). carbon hydrogen” (European Commission 2022b).

Regulatory clarity and predictability are in this sense The central legislative basis for certification of renewable
crucial for the global hydrogen economy, especially hydrogen is included in the current Renewable Energy
considering the EU’s role as one of the leading hydrogen Directive (“RED II”). The directive was designed to promote
importers of the future. A lack thereof could strongly and increase the share of renewable energy in the EU´s
jeopardize the global market ramp-up, as certainty about the energy mix up to 32% by 2030. RED II sets the baseline for
exact criteria for green and low-carbon hydrogen required to the definition of criteria for the production of renewable
be eligible for the EU market is a precondition for increased liquid and gaseous transport fuels of non-biological
investments in exporting nations (Gherasim 2022; Tovar origin (RFNBO) used in the transport sector. This also
2022). EU member states therefore voiced their support early entails general criteria for green hydrogen and its
on for a harmonized European certification scheme derivatives to be counted towards the renewable energy
(Pentalateral Energy Forum 2021). targets and to be considered for green hydrogen support
schemes. RED II is thus the starting point for hydrogen
Following the Green Deal, the EU passed the “Hydrogen certification on the EU-level.
Strategy for a climate-neutral Europe” in July 2020, setting
out pathways of how the production and usage of green The regulatory framework for specific criteria for green
hydrogen could contribute to achieve the objectives set out hydrogen is determined in two delegated acts (DA)
in the Green Deal and decarbonize different industry sectors under Art. 27 and 28 of the RED II (Heinemann et al. 2022;
and transport in the EU. The EU hydrogen strategy (European Klessmann et al. 2022). The two DAs were published in
Commission 2020) foresees a production of up to 10 February 2023 by the European Commission. They are still
million tons of green hydrogen in the EU by 2030, with pending the approval by the European Parliament and the
the definition that it must be “hydrogen produced through European Council to enter into effect in June 2023.
the electrolysis of water (in an electrolyzer, powered by
electricity), and with the electricity stemming from renewable The DA on Art. 27 sets out the “requirements for renewable
sources.” The strategy also acknowledges that in the short- electricity used to produce these renewable transport
and medium-term low-carbon hydrogen (using CCS in the fuels so they can be counted as fully renewable” (European
production) would be needed. However, the main focus Commission 2023a). The criteria set out in the DA explicitly
remains on green hydrogen and even though “appropriate applies to both domestically produced and imported RFNBOs.
support would be needed for low-carbon hydrogen, […] this One of the core ideas is to assure that the energy used for the
production stems from additional renewable capacities
19

specifically dedicated towards RNFBOs. The reasoning located when operation started) in the same bidding zone, an
behind this approach is to avoid the cannibalization of interconnected bidding zone when the electricity prices on
emission savings with the use of already existing renewable the day ahead market are equal or higher or an
electricity sources and thus a possible increase of emission interconnected bidding zone in case of an offshore bidding
intensive electricity sourcing in other market segments. The zone (Scheyl 2022; Friese and Scheyl 2022; European
DA itself differentiates between different cases for Commission 2023a).
electrolyzes, sourcing renewable electricity through a direct
connection or an indirect connection via the grid or through Following this, the DA on Art. 28 of the RED II, focuses on a
PPAs. It defines different requirements for these cases under “methodology for GHG savings [which] puts forward a
which the electricity used can be counted as fully renewable. detailed scheme to calculate the life-cycle emissions of
The carbon intensity of the electricity input is defined as zero renewable hydrogen” (European Commission 2023b). It
as long as the electricity used is labeled as fully renewable determines the amount of GHG emissions savings from
under the provisions set out in the DA on Art. 27. This is key RFNBO, including green hydrogen, but also eligible carbon
for the calculation of life-cycle emissions of renewable sources and regulations for co-processing. A life-cycle
hydrogen established by the DA on Art. 28 (Sailer 2021; Scheyl approach is taken, covering the entire life cycle of the RFBNO
2022). and includes emissions from input, processing, transport and
distribution, combustion as well as savings from CCS. The
For both direct and indirect connections, the central provision GHG footprint reduction from the use of RFNBOs must be
is that the supplying power plants must have be max. at least 70% compared to fossil fuels. With the reference
commissioned 36 months before the electrolyzer. For indirect value for the fossil fuel comparator of 94gCO2e/MJ included
connections, the requirements of renewability, in the DA on Art. 28, a threshold below 28.2gCO2e/MJ can
additionality, as well as temporal and geographical be deducted (Friese and Scheyl 2022; Scheyl 2022).
correlation must be respected. An exemption was included
for electrolyzers being located in a bidding zone with an Once the DAs have final approval by the European
average emission intensity of 18 gCO2/MJ or lower, under the parliament and European Council, the implementation of
provisions that the electricity was supplied via at least one PPA the actual certification system will follow. The Commission
and the requirements for temporal and geographical is set to recognize voluntary schemes, which can be either
correlation are met. Detailed exemptions also apply for national (e.g. in Italy) or privately run (e.g. ISCC, TÜV SÜD)
electrolyzers with grid connections via PPAs, located in a and will develop actual tangible criteria out of the
bidding zone with an average share of over 90% renewables regulatory framework for the producers to fulfil. These
in the last year or in certain cases of downward re- schemes will then appoint certification bodies to carry out
dispatchment of renewable energy sources. As mentioned the necessary audit procedures. Europe is already leading
above, the requirement for additionality entails that the with regards to the implementation of such schemes, in
supplying power plants must have been max. commissioned 2021, 13 schemes have already been positively assessed
36 months before the electrolyzer. The addition of capacities under RED II by the Commission and could seek official
is allowed within a further 36 months. Furthermore, the power recognition after the publication of the beforementioned
plant may not receive capital expenditure (CAPEX) or delegated acts. (Sailer 2021; Sailer et al. 2022). The CertifHy
operational expenditure (OPEX) support (exceptions e.g. for scheme already announced to do so and is the most
grid access or R&D facilities). However, as an incentive for prominent scheme on the EU-level with a pan-European
first movers, RNFBO producers which have started operation scope. It has been initiated by the EU-Commission itself to
before 2028 are exempt for this criterion until the end of 2038 foster the development of certification schemes. It has set
(Sailer 2021; Friese and Scheyl 2022; European Commission the emission threshold for the certification of green
2023a). hydrogen, before the final publication of the delegated acts,
at 36.4 gCO2-eq/MJ (Heinemann et al. 2022; Piria et al. 2021).
The requirement for temporal correlation was included to
prove the alignment between the actual production of RNFBO 4.3.2 Germany
and the previous consumption of renewable electricity.
Generally, the RNFBO will have to be produced in the same As many countries in the EU, Germany will also be a future
one-hour period as the renewable electricity or from hydrogen importer. Green hydrogen will play a significant
renewable electricity from a storage asset (charged during the role in the decarbonization of German heavy industry and
same one-hour period) located behind the same network the attainment of Germany’s Net Zero goal. Therefore, the
connection point as the electrolyzer. Until December 31, 2029, establishment of hydrogen certification as a fundament for
one month will be applied. A last option to fulfill the hydrogen production and trade is of high importance to the
requirement refers to certain circumstances with low energy German government.
prices, as it was argued that in this case fossil-based electricity
production would not be economically attractive and The importance of hydrogen certification is further
additional electricity demand from the electrolyzer would strengthened by Germany’s decision to focus exclusively
stimulate further production of renewable energy. For the last on green hydrogen to achieve its Net Zero targets. While
requirement of geographic correlation, the power plant the German National Hydrogen Strategy from 2020 already
and RFNBO production need to be located (or were previously pointed out that only green hydrogen could be
20

sustainable in the long run (Bundesregierung 2020), the adds a colour label depending on the production itself.
Ministry for Economic Affairs and Climate Action announced There is no clear threshold in terms of emissions before off-
in January of 2022 that all German support programs will be setting, but there are different sub-categories depending on
limited to green hydrogen only. This necessitates the rapid the feasibility of carbon emission calculation along the value
establishment of certification schemes to ensure both the chain (TÜV Rheinland 2021). TÜV Süd on the other hand, has
targeted domestic green hydrogen production capacity of a dedicated standard of a reduction of at least 70% com-
10 GW by 2030 (Kurmayer 2022) as well as the ramp up of an pared to the RED II reference value (94 gCO2eq/MJ), mean-
international market. ing 28.2 gCO2eq/MJ (TÜV SÜD 2021). Furthermore, the TÜV
Süd certification is limited to green hydrogen produced
While Germany has put its focus on green hydrogen and through renewably powered electrolysis as well as steam re-
only sees green hydrogen as sustainable in the long run, to forming and pyrolysis using biomass. Its calculations do not
foster the market ramp up of hydrogen and meet the include the setup of production facilities or transport, but the
demand for hydrogen in a transition period, the German latter is included in a separate TÜV Süd certification which is
government is discussing support for blue hydrogen, called GreenHydrogen+. In April of 2022, TÜV Rheinland is-
especially in relation to the build-up and usage of hydrogen sued the first ever green hydrogen and ammonia certifi-
infrastructure. The update to the National Hydrogen Strategy cation to a planned 300MW electrolyzer facility in Oman
was not yet available at the time of publication of this study (Hydrogen Technology Expo 2022).
(BMWK 1/5/2023).
For the German private sector certification schemes, a mean-
As a first step towards the ramp-up of domestic green hy- ingful connection to the future EU certification system as well
drogen production, the German Ordinance on the imple- as the CertifHy pilot is key, which is why the existing certifi-
mentation of the Renewable Energy Act establishes a clear cation schemes by TÜV Süd and Rheinland are set to be con-
definition for green hydrogen in §12. According to the Or- nected with the CertifHy system. TÜV Süd is directly involved
dinance, hydrogen produced with electricity from 100 % re- the initiative as one of the project partners (Vanhoudt 2016)
newable sources, to be proven through a guarantee of and supports the establishment of a EU-wide system
origin, is exempted from the renewable energy levy (Bun- through CertifHy. As part of the initiative, a facility in Falken-
desregierung 2021). The Ordinance also includes a provision hagen, Germany, is one of the two green hydrogen pilot pro-
stating that this definition will be revised according to EU jects certified (Vanhoudt 2016)
standards as soon as they are agreed upon, underlining the
importance of EU-wide collaboration on this issue. In the The importance of the CertifHy project is also mirrored in bi-
summer of 2022, the German Bundestag furthermore agreed lateral initiatives. A cooperation between the German (DENA)
on the so-called Immediate Measures Act, which includes the and Australian Energy Agencies for example aims at creating
provision for a legal definition of green hydrogen, which is to a joint certification system for hydrogen based on CertifHy
be established through an additional ordinance (Zwanziger (Varma and Boldis 2021).
and Wilden 2022).
German industry largely supports the government’s per-
While this definition is likely to support the establishment of spective on the importance of hydrogen certification. In-
domestic production capacity, internationally agreed-on dustry representatives see a certification system for hydro-
and applicable hydrogen certification will be necessary gen as vital for the establishment of a hydrogen econ-
to establish global hydrogen trade. The importance of omy. In a “Green Hydrogen Manifesto”, which the German
such a certification as well as international cooperation in Hydrogen and Fuel Cell Association published together with
this regard was already pointed out in Germany’s National Hydrogen Europe, the need for a comprehensive certification
Hydrogen Strategy (Bundesregierung 2020). Particularly the scheme is particularly underlined (Hydrogen Europe et al.
European context is crucial. Despite Germany being the con- 2021). The Association furthermore stresses the need for co-
tinent’s leading hydrogen economy, a nationally limited hy- operation, in particular in Europe, to ensure a timely market
drogen certification system would be inefficient at address- ramp up of green hydrogen (Deutscher Wasserstoff- und
ing the needs of an international market, especially given Brennstoffzellen-Verband 2021a), while furthermore welcom-
that the EU is a single trading block. Therefore, Germany is ing the provisions on requirements for green hydrogen as
heavily involved in broader European initiatives on hy- spelled out in the Renewable Energy Act Ordinance
drogen certification and definition, as described earlier. (Deutscher Wasserstoff- und Brennstoffzellen-Verband and
performing energy 2021). Some firms would, however, like to
What makes Germany special in the wider EU context is, see blue hydrogen being included in Germany’s funding
however, that the private sector in Germany is among the schemes (Boldis and Graf 2022). This, nevertheless, appears
trailblazers of hydrogen certification. Most notably, TÜV to be limited to individual stakeholders, as most of the de-
SÜD as well as TÜV Rheinland have already established a bate is instead centred around detailed provisions, such as
standard for green hydrogen, which follows German and EU the need for an exclusively green hydrogen distribution net-
regulations, but is open for other nations as well (TÜV SÜD work (Boldis and Graf 2022) or specific conditions on pro-
2022). In this regard, TÜV Rhineland certifies carbon-neutral curement spelled out in the previously mentioned Renewa-
hydrogen of different production methodologies if the emit- ble Energy Act Ordinance (Deutscher Wasserstoff- und
ted life-cycle carbon emissions are directly compensated and Brennstoffzellen-Verband 2021b).
21

5 Conclusion: Possible further steps and

areas to address together.

5.1 Comparison for the currently discussed Korean certification threshold as

well as 41 gCO2eq/MJ for the suggestion of the China
All countries we analyzed underline the importance of Hydrogen Alliance over 36.4 gCO2eq/MJ for the EU’s
hydrogen for decarbonization, while most have CertifHy, ca. 33g CO2eq/MJ for the US Draft Standard,
acknowledged the need for hydrogen certification in some 28.3g CO2eq/MJ for the proposal of the Japan Hydrogen
way and stress its importance in different forms. However, Association to 28.2gCO2eq/MJ for the currently discussed
the study has also shown that there are considerable EU threshold and TÜV Süd’s certification. The lowest
differences between strategies as well as the level of thresholds thus far are the EU’s currently discussed
progress countries have achieved with regards to the threshold, which is expected to be 28.2gCO2eq/MJ, the limit
implementation of hydrogen certification. for the highest US tax credit, namely 3.75gCO2eq/MJ,
and the German focus on exclusively green hydrogen. All
A commonality is that most countries seek to contribute thresholds are also compared in the graph below.
to international standardization and certification
initiatives, which underlines the importance of a unified For the thresholds, the scope of the covered emissions,
global approach. Some experts (Sailer et al. 2022), however, however, also must be considered. Even though the scope
believe that a global harmonized scheme is unlikely often differs in detail, it is generally differentiated between
because forerunners will not reduce their ambitions for such well-to-wheel and well-to-gate approaches. The former
a scheme, while others might be unwilling to become more means that production emissions, as well as transport and
ambitious. Actively engaging in in existing formats towards supply up to the end use are accounted for, while the latter
a harmonization – such as in the context of IPHE – is includes only everything up to – and including –
nevertheless crucial, both to push for more ambition and to production. As of January 2023, the Korean Certification
jointly advance hydrogen certification as a foundation of System, the US, the proposal of the Japan Hydrogen
future hydrogen trade. Association and CertifHy use a well-to-gate, TÜV Süd and
the China Hydrogen Alliance a well-to-wheel approach.
At the same time, however, there are individual trailblazers
in each region, which have already started to implement
Suggested certification thresholds for low-
certification systems. These trailblazers offer great
carbon hydrogen (gCO2eq/MJ)
opportunities for mutual learning and can become 60
crystallization points of regional or global considerations
regarding hydrogen certification. In addition, the progress
42
41
36,4

the EU has made regarding the establishment of

40
33
28,3
28,2
28,2

supranational certification can serve as a blueprint and

inspiration for similar approaches.

It is also worthwhile to note that private actors have often 20

also stepped forward, underlining the importance of
3,75

certification on the one hand, and developing own

certification schemes on the other. Especially smaller
countries or interested private actors from countries which
0
still have to move towards the implementation of Threshold for the highest possible tax credit (US, well-to-gate)

certification could rely on these certification programs as Tentative Standard (EU, well-to-wheel)

starting points, especially when they are aligned with TÜV Süd (private, Germany, well-to-wheel)
overarching initiatives, e.g. the EU’s CertifHy initiative. Proposed Standard Japan Hydrogen Association (well-to-gate)

Draft Standard / threshold for lowest tax credit (US, well-to-gate)

A range of initiatives, countries and certification systems CertifHy Standard (EU, well-to-gate)
have also put certification thresholds for low-carbon Hydrogen Alliance Suggestion (China, well-to-wheel)
hydrogen forward. To make them comparable, the Tentative Certification Threshold (Korea, well-to-gate)
thresholds have been converted to CO2eq/MJ, assuming an
Figure 1: own illustration by authors
energy density of 120 MJ/kg for hydrogen. Using this
conversion, the thresholds range from ca. 42 gCO2eq/MJ
22

5.2 Recommendations and potential for Lastly, international initiatives focusing on the advancement
of hydrogen certification should continue to seek building
cooperation
bridges between existing initiatives, aiming to ensure
future compatibility between them. Using existing
The findings of this study highlight a number of potential
approaches and experiences as a foundation for own
topics and areas for collaboration. From the perspective of
suggestions, e.g. on methodologies, could not only facilitate
individual countries, the study provides useful starting points
their development. It could also ensure that they will be
for the further advancement of certification initiatives. First of
employed by the first movers on the low-carbon and
all, it might make sense to further support international
green hydrogen market. It is to assume that these first
efforts towards certification. After much progress has already
movers will set the standards for others following later,
been made in the context of a generally recognized emission
which necessitates that international solutions are in line
calculation methodology in IPHE, the most important aspect
with approaches currently being tested and implemented.
of future cooperation would be the mutual recognition of
national certification systems and bodies – irrespective of
individual national thresholds. If the leading hydrogen
economies manage to establish an international standard of
certification which enables certifications to be mutually
recognized, international trade of hydrogen would be greatly
facilitated, while still allowing for a divergence of national
thresholds. Additionally, cooperation opportunities also
present themselves in the context of monitoring, as this will
be crucial to ensure the agreed-on guidelines in a global
market.

At the same time, it might be sensible to reach out to

certification trailblazers, both internationally as well as
within the own region or country. Even though the topic is
comparatively new, some actors have already made
considerable experiences and learning from them could
accelerate and streamline own considerations. A range of
technical details could be the focus of such collaboration
initiatives, for example:

• Development of a methodology for the

calculation of the CO2 footprint of hydrogen.
• Establishment of monitoring systems.
• Inclusion of hydrogen standards into government
procurement and funding programs.
• Development of certification schemes.

Additionally, individual countries could use existing private-

sector certification schemes or suggested international
methodologies for pilot projects and bilateral cooperation
projects in order to both validate and test these
suggested approaches. This would also underline the
importance of hydrogen certification and could contribute to
the advancement of the topic.

Another potential point for future discussions is the level

and future development of low-carbon hydrogen
thresholds. As seen in Figure 1, there is some difference
between approaches, and it might be sensible to discuss
these in the context of hydrogen’s role towards net zero.
While they might be indicative of different national
decarbonization strategies at the moment, such discussions
could also focus on the way forward and in particular the
perspective of such thresholds in the medium run and until
2050 under consideration of net zero targets.
23

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