The German Renewable Energy Association (BEE) has raised concerns about the draft of the guarantee of origin for electricity used in green hydrogen production, warning that it contains critical loopholes.
According to BEE President Simone Peter, the proposed Guarantees of Origin Register Regulation is not stringent enough and could potentially undermine the credibility of green hydrogen. She stated that without revisions, it could lead to a significant decline in the quality of green gases, particularly those derived from electrolysis plants powered by renewable energy.
Green hydrogen production is critical not only for reducing carbon emissions but also for supporting the energy grid and minimizing grid expansion costs. However, the draft regulation falls short of ensuring that the energy used in hydrogen electrolysis originates from renewable sources.
Peter stressed the need for a clear definition of the energy’s origin used in hydrogen production and for it to be linked to specific geographic locations and timeframes to address local grid bottlenecks, which would make hydrogen production more future-proof.
One point of contention is the requirement for physically delivering green electricity to hydrogen production sites. The draft does not clarify that the electricity for electrolysis merely needs to be supplied to the local grid as green energy, not physically delivered. The regulation should take into account that verifying physical delivery is neither feasible nor practical for producers.
Furthermore, the draft should prohibit the sale of guarantees of origin to third parties after the producer has consumed the energy. Without these modifications, the draft legislation opens the door to potential greenwashing and raises concerns about the overall credibility of green hydrogen produced in Germany.
The green hydrogen sector is rapidly gaining importance worldwide as a key component of clean energy transitions. As more industries and transportation modes look to reduce their carbon footprint, stringent regulations and transparent practices in green hydrogen production are vital for building trust and ensuring environmental benefits are achieved.
Germany, like many other nations, is striving to play a leading role in green hydrogen production. However, to achieve this goal, it must establish comprehensive and credible regulatory frameworks that address issues like the origin of energy sources used in electrolysis, proof of delivery, and the sale of guarantees of origin.
