Draft threshold is so low that it would shut the door to hydrogen produced from the power grid, even in places like France and the Nordic countries which have a low-carbon electricity mix. Signatories are concerned that the currently proposed criterion of 2.256 kgCO2eq/kgH2 largely pre-empts the regulatory debate to take place with respect to the EU hydrogen framework and undermines the EU leadership ambition whilst unnecessarily limiting business options compatible with Paris-aligned business trajectories. The threshold in the taxonomy is also at odds with the European Commission’s own hydrogen strategy unveiled last year, which aims to rapidly scale up the production of hydrogen in Europe, using renewables and other low-carbon sources of electricity. The benchmark set in the taxonomy is so low that even solar power would fail to meet the requirement
Grid connected electrolysis is excluded, even with grid carbon intensities as low as 100g/kWh. The European Commission needs to clarify whether the emission standard in the taxonomy is related to process or lifecycle emissions. It would of course make more sense to have a criterion that encompasses the entire lifecycle. 2.256kgCO2/kgH2 does indeed unnecessarily restrict business options, implicitly excluding blue hydrogen and grid connected electrolysis. The Commission can still decide to push up the threshold during the starting phase of the EU hydrogen market, and gradually tighten the screw over time as the market grows and production volumes increase.