Additionality of renewable electricity for green hydrogen production in the EU

Hydrogen produced from renewable electricity could play a major role in sectors that cannot easily be directly electrified. As long as renewable electricity is scarce, choices will have to be made about where the next available renewable electricity capacity will be applied. In this context, the concept of additionality refers to the requirement that new electrolysers producing renewable hydrogen must be supplied with electricity from new, dedicated renewable sources.

In this study we found that strict adherence to the additionality requirement is necessary in order to minimise CO2 emissions during the energy transition. There are two main reasons for this:

  1. In most EU Member States, electricity is still produced from fossil fuels for significant periods of time and producing hydrogen from fossil electricity generates far more CO2 emissions than producing it directly from natural gas.
  2. The use of hydrogen only leads to a limited reduction in end-use emissions.

We then assessed the criteria for electricity to be counted as renewable, as presented in the European Commission’s draft Delegated Act on Additionality on May 20th, 2022. We concluded that these criteria by themselves are robust and would guarantee additionality, as long as they are not compromised. Although the transitional phase proposed in the draft Delegated Act would temporarily suspend the additionality requirement, its impact on emissions is likely to be limited. The grandfathering clause (Article 8), however, would threaten the preservation of additionality more seriously while it is not bound by an end date.

We have positioned our study in the context of the dual ambitions of the European Commission, related both to the large-scale deployment of renewable energy in general and to the rapid development of the production and use of renewable hydrogen in the EU. One of our findings is that the Commission’s own projections for new renewable electricity capacity in 2030 are insufficient to fully decarbonise the power sector, meet the new demand for electrification and produce the desired 10 million tonnes of renewable hydrogen in the EU.