The title ‘renewable fuels of non-biogenic origin’ already makes it clear that this is not a definition of green hydrogen. Rather, the document specifies the conditions under which electricity-based fuels – and thus also derivatives of electrolysis hydrogen such as e-fuels – are recognised for certain advantages. These include tax advantages, crediting towards expansion targets, and consideration in the context of GHG reduction targets through instruments such as GHG quota trading.

Hydrogen from electrolysis can receive these benefits if it is produced (in simplified terms) as follows:

  • by directly purchasing electricity from a renewable energy plant (RE) without a grid connection,

  • by using grid electricity in a bidding zone with more than 90% renewable energy share,

  • by purchasing renewable energy via a power purchase agreement (PPA), or

  • through electricity, the reduction of which avoids the curtailment of a renewable energy plant as part of a redispatch measure.

The actual regulations are significantly more complex and currently pose a major challenge for all electrolysis operators – a more detailed explanation would go beyond the scope of this article. However, it is important to note that there is another method currently recognised by the EU.