Europe’s green hydrogen

Almost five years after the publication of RED II (Renewable Energy Directive), three years after the announcement of Europe’s ambitions in hydrogen, two years after the entry into force of RED II, more than two years after the inclusion of hydrogen in the French energy code, one year after the Commission authorised public aid of up to 5.2 billion for the H2Use IPCEI (Important Projects of Common European Interest) for the production of renewable hydrogen, and after years of preparation, discussions, consultations and a spectacular turn of events, the European Commission’s delegated acts defining the criteria for specifying renewable hydrogen and classifying its derivatives produced in Europe (or imported) were finally published on June 20th.

Europe finally has a definition for renewable hydrogen! Hallelujah !

This newly certified hydrogen will therefore add a new hue to the already diverse H2 kaleidoscope: “Green Europe”. Positioning this colour on the colour chart can sometimes become a difficult exercise, often subjective and regularly susceptible to regional colour blindness. While each country will certainly see its hydrogen in a beautiful spring green, some (on the other side of the Rhine?) will think they see French hydrogen tending towards pink, while many other products will appear in much darker shades, or even a dubious yellow.

The text of these delegated acts does not lead naturally to serenity. These abundant and complex rules (21 pages) provide for several ways of supplying electrolysers with renewable electricity, depending on whether they are connected physically (direct line) or virtually (Power Purchase Agreements) to solar or wind farms, or are used to provide flexibility to the grid during periods of congestion.

These regulations, which apply to both domestic production and imports into the EU, are already having an impact outside Europe, with intense debates in the United States about the possibility of introducing similar rules – such as the ‘additionality’ and spatio-temporal correlation criteria – or in Japan, which has decided to adopt a similar threshold of 3.4 kgCO2eq/kgH2 (-70% GHG) to define the decarbonised nature of the hydrogen produced.

A great deal of work remains to be done to achieve an international harmonisation of standards.

Under particular scrutiny, these rules finally define renewable hydrogen within the meaning of this directive. And should, therefore, begin to provide the stability and legal certainty so eagerly awaited by investors and manufacturers, without which business models and investment decisions could not be completed. These delegated acts finally specify the conditions under which electricity drawn from the grid can truly be considered renewable. However, given the complexity of this text and the controversies that still surround it, the debate on electricity and greener-than-green hydrogen will not be over with the publication of this text. The enthusiasm shown by Mrs Kadri Simson’s (European Commissioner for Energy), who expressed her delight on Twitter when the texts were published, should be tempered: “This means legal certainty for producers and consumers of renewable hydrogen and is a crucial step in attracting investors…“.

In the general case, electricity must be purchased “directly or indirectly” from one or more additional renewable sources. For the Commission, this means: (i) unsubsidised, (ii) commissioned at the same time as the electrolysers (with a tolerance of 36 months), (iii) geographical correlation must be respected (~same bidding zone, country), and finally (iv) time correlation that should eventually be (2030) on an hourly basis.

We note that these criteria are particularly suitable for projects that are sometimes described as “neo-colonialism energy”, allowing “green” production to coexist with an electricity system that is rich in CO2 emissions (in this case, this “green” hydrogen would have to be subject to the Carbon Border Adjustment Mechanism, but that’s another story), but seem particularly unsuitable in European countries developing renewable energies mainly via feed-in contracts, often in the form of two-way CfDs[1]

In practice, these delegated acts contain two important pragmatic provisions:

  • Any project commissioned before January 1st, 2027, will be able to use “non-additional” renewable electricity, i.e., electricity that may have been commissioned long before the startup of the electrolysers and that may have benefited from subsidies, until January 1st, 2038.
  • Above all, these acts grant special status to reward electricity mixes that are already decarbonised, either through a very high penetration of renewables or a mix of renewables and nuclear. Projects located in countries (bidding zone) where the intensity of emissions attributable to the electricity produced is less than 18 gCO2eq/MJ (64.80kgCO2eq/MW) will be able to use “non-additional” renewable electricity.

Metropolitan France should be below this threshold, but we still need to agree on the emissions factor for the French mix. In the annex, the Commission proposes a high factor (19.6gCO2eq/MJ), making no distinction between mainland France and the French overseas territories. However, the rules allow for the use of alternative methods and data sources, which should enable the emission factor of the grid to be recognised at its true value by restricting its scope to mainland France (bidding zone).

Guarantees of origin

This delegated act remains relatively quiet on the use of guarantees of origin in its requirement to conclude “directly, or via intermediaries, one or more renewables power purchase agreements with economic operators producing renewable electricity in one or more installations generating renewable electricity for an amount that is at least equivalent to the amount of electricity that is claimed as fully renewable and the electricity claimed is effectively produced in this or these installations”.

This reference to guarantees of origin is only present under premise 15 of this delegated act: ” Article 19 [of RED2] should avoid that both the producer of the renewable electricity and the producer of the renewable liquid and gaseous transport fuels of non-biological origin produced from that electricity can receive guarantees of origin by ensuring that the guarantees of origin issued to the producer of renewable electricity are cancelled”.

Although it is not explicit, we therefore understand that the renewable nature of the electricity purchased “directly or indirectly” from one or more renewable sources and consumed by electrolysers will have to be proven by a corresponding guarantee of origin. Based on the characteristics of this guarantee, the additionality and spatio-temporal correlation requirements can be verified.

Therefore, for France (subject to emissions intensity being well below 18gCO2eq/MJ) we understand that the conditions of this delegated act will be fulfilled if the “intermediary” (supplier) cancels an amount of guarantees of origin from France each month for a quantity equivalent at least to the amount of electricity declared as entirely renewable.

From 2030, the time correlation should be hourly, which should lead to a change in the organisation of the system of guarantees of origin in France (they are currently issued on a monthly basis).


This delegated act continues to be the subject of much (justified) criticism, particularly from the European Parliament, and it is highly likely that this standardisation work will be amended before the end of the transitional phase (in 2027). There is even talk of one of the articles of RED III (currently being finalised) cancelling and replacing this delegated act.

Does Europe have a definition for renewable hydrogen?

[1] Contract for Difference

Philippe Boulanger

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Profesional Experience & Education

Diego graduated in Political Economy at King’s College University (London – 2021). He started his professional career in a family business in Madrid as an operations manager. Diego then studied a Master in Management and Master in Computer Science at IE University (Madrid – 2022), during which he participated as an Information Technology (IT) intern in a startup. In May 2023, Diego joined the HES team as an intern specialised in programming models. In his first project, he developed a software tool for modelling the unavailability of the French nuclear fleet. Afterwards, Diego has also participated in the development of new software tools for modelling price curves, generation asset performance and other topics related to the energy market. 

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Diego Marroquín

Profesional Experience

Céline joined Haya Energy Solutions in November 2021 as marketing and administration manager. She had a first professional experience in the tourism sector as a social media manager. At HES, her activities are focused on the development of the company’s visibility at European level through: commercial actions, content marketing and development of brand strategy. Céline is also involved in the management of the company’s communication: optimisation of the website (WordPress & Elementor), LinkedIn, publication of the monthly newsletter and the organisation of conferences. Céline participates in energy projects with the clients and acts as coordinator and project manager. Finally, she is in charge of administration (accounting, expenses management, invoicing).   


Céline graduated in Spanish and English Philology at La Sorbonne (France – 2018) and holds a Master’s degree in Project Management and Cultural Tourism (Clermont-Ferrand/ Buenos Aires – 2021). 

Céline Haya Sauvage

Marketing Responsible

Céline Sauvage

Investment Advice

“Decarbonization of the Energy and Transport sectors is arguably today’s main economic driver for the industry.”

Profesional Experience

His career started in civil engineering as a Project Manager in France, Martinique and Australia. Afterwards, he became the General Manager of a subsidiary in Venezuela. In 1992, he established Dalkia in Germany (district heating, cogeneration, and partnerships) and represented Véolia in Thailand. In 2000, he opened the commercial office of Endesa in France to take advantage of the liberalized retail market. From 2006, as a development Manager at Endesa France, he led Endesa’s plan for Combined Cycle generation in France and developed the wind and PV portfolio of Snet at the same time. Philippe Boulanger worked for 3 years at E.ON’s headquarters coordinating the company´s activities in France. He was strongly involved in the French hydro concession renewal project. As a Senior Vice President – Project Director at Solvay Energy Services from April 2012 to February 2014 he was in charge of the H2/Power to gas and European direct market access deployment projects. Philippe has been an HES expert since 2014.


Philippe Boulanger holds engineering degrees both from the Ecole Polytechnique and the Ecole Nationale des Ponts & Chaussées (France) and has a combined experience of more than 25 years in energy and infrastructure. In addition to English, Mr. Boulanger is fluent in French, German & Spanish.

Philippe Boulanger

Electricity Expert


“The world is changing. New investors pay particular attention to the energy sector while historical actors adapt their position to the market.”

Profesional Experience

Antonio started his career in the electricity sector in 1991 working as a member of the General Manager’s team at Sevillana de Electricidad (Spain). In 1997, he was appointed head of commercial regulation at Endesa Distribución. In 2000, he joined the mergers and acquisitions (M&A) department of Endesa Europe. He was appointed Managing Director of Endesa Power Trading Ltd (UK) in 2003. A year later, he became responsible for energy management at SNET (France). In 2008, he was appointed Managing Director of SNET (France). In 2009, he became Director of Corporate Development at E.ON France. In 2011, he founded Haya Energy Solutions (HES), a consulting firm focused on optimising the energy management of consumers, producers and retailers of gas and electricity. From 2015 to 2018, Antonio combined the consulting activity at HES with the general management of 2 production facilities in France (2 CCGTs x 410MW), owned by KKR. At the end of 2018, he joined Asterion Industrial Partners, an infrastructure investment fund, as an operating partner. Antonio currently devotes most of his efforts to the Asterion Portfolio, while advising through HES companies in the energy sector in France, Italy, Germany, UK and Spain. 


Antonio graduated from the Escuela Técnica Superior de Ingenieros of Seville (Spain) and holds an MBA degree from Deusto University (Spain). 

Antonio Haya