Hydrogen plays a crucial role in climate protection and secure energy supply in Germany and Europe. As part of its national hydrogen strategy, the German government is promoting the expansion of infrastructure and advocating for uniform certification of the origin of hydrogen produced from renewable electricity by means of electrolysis, known as ‘green hydrogen’.
Legal requirements and Delegated Act on green hydrogen
There are no specific legal requirements for green hydrogen as yet. § 93 of the EEG 2023 currently only contains the ‘regulatory authorisation for requirements for green hydrogen’. In addition, Commission Delegated Regulation (EU) 2023/1184 of 10 February 2023 (Delegated Act) came into force on 10 July 2023, defining criteria for renewable fuels of non-biogenic origin for transport (RFNBO). A very timely amendment to the 37th BImSchV to implement the Delegated Act was already announced by the BMUV in the spring.
The criteria listed in the Delegated Act initially apply only to use in the transport sector. However, compliance with these criteria is already mandatory in numerous subsidy programmes, regardless of the sector of application.
Why conduct an external review of the criteria for green hydrogen?
Projects and products that do not meet the criteria of the Delegated Act will experience lower acceptance. Anyone who wants to plan a future-proof electrolysis plant, for example, should ensure that the criteria of the Delegated Act are already met.
We expect secure requirements for verification to be introduced in the future, similar to the BioKraft-NachV. Voluntary systems such as ISCC-EU or REDcert-EU will play an important role here in the future, once the criteria have been adapted.
However, as an environmental verification organisation and accredited verification and certification body, GUTcert already audits and validates projects, plants and products in connection with green hydrogen and the criteria of the Delegated Act.
Marketing green hydrogen via the dena biogas register
Hydrogen can also be balanced and marketed via the dena biogas register. We expect the criteria to be adjusted in the near future. As long-standing experts, we are happy to support you with assessments in the dena biogas register.
Please feel free to contact us so that we can answer your questions about hydrogen certification and work out a tailor-made solution together.
