Eight criteria for the import of green hydrogen into the EU.
Christoph Heinemann is an expert on the production and use of hydrogen as a climate protection tool. Dr Roman Mendelevitch is an expert on international energy commodity markets. Both scientists work in the field of energy & climate protection
Cross-posted from the website of the Oeko-Institute. Read the complete working paper here
The impact of bulk hydrogen production on the exporting countries is significant (see Figure 1-1):
for the import of around 170 TWh of hydrogen, around 50 million cubic metres of water must be
provided in these countries and around 260 TWh of electricity must be generated from renewable
energies. This corresponds roughly to a capacity of 85 GW of onshore wind turbines. By comparison,
wind turbines installed in North Africa at a capacity of 3 GW generated around 8 TWh of electricity
in 2020. Currently, the policy focus is on the use of green electricity to produce green hydrogen.
There is more to sustainable green hydrogen than just using renewable electricity
• Electricity is the main input into the electrolysis but is also needed for other processes within the
hydrogen value chain such as seawater desalination or when producing derivatives from
hydrogen. Electricity supply from renewable energy sources can conflict with the decarbonisation
of the domestic energy system . Especially when sourci ng electricity from the electricity grid,
hydrogen production can cause additional GHG emissions or contribute to bottlenecks.
• Water is needed as feedstock for the electrolysis but also for cleaning PV panels. Even though
the amount of water needed for hydrogen production is low compared to other uses (such as
agriculture), local water stress is a serious issue for many countries with high hydrogen export
potential. Risks relate both to the physical availability of water and the economic pressure on
scarce water resources.
• Land is mainly needed for renewable electricity production. Land -use change can interfere with
biodiversity or local (sometimes informal) land rights.
• Socio-economic impacts will accompany the build-up of a hydrogen export value chain. Human
rights could be particularly at risk when it comes to land-use change as well as in work processes
along the whole value chain. In addition, there can be a lack of (economic) participation of local
people related to local jobs or transfer of technology and know-how.
• CO2 is needed as an additional input to produce derivatives from hydrogen. If fossil CO 2 is used
that results from burning fossil fuels, the decarbonisation of the economy might be delayed.
• Transport of hydrogen or derived products can be dangerous for workers and the environment in
case of accidents (for example if ammonia is being transported).
• Raw materials are needed to produce electrolysers and renewable power plants. Some of these
materials are mined under unacceptable working conditions, mines contribute to pollution and are a risk to health. Iridium is used in some electrolysers and could be a limitation to the uptake of
hydrogen production due to its low availability.
Eight criteria for sustainable green hydrogen, building on existing regulatory frameworks:
Options for specific criteria are the following (see Figure 1-2).
• At country level, we propose to ask hydrogen trading partners to develop a decarbonisation
strategy that also takes hydrogen production into account. This strategy should be analysed
through a Strategic Environmental Assessment (SEA). If major concerns are identified in this SEA,
the trading partners’ strategy should be adjusted.
• At the project level an Environmental Impact Assessment should be carried out. This could be
complemented by a Sustainability Impact Assessment that also includes socio -economic
dimensions. Consultation of local stakeholders and suitable grievance mechanisms should be
• Electricity input to hydrogen production should be based on additional renewable energy sources.
In case of sourcing electricity from the grid, provisions of the RED addressing system integration
and grid bottlenecks should be consi dered. Additional instruments should make sure that the
allocation of dedicated renewable sites for hydrogen production does not impede domestic
decarbonisation. Additional investment in local infrastructure (such as renewable electricity
generation, energy grids, electricity storage systems) could support local sustainable
• Water should be sourced from additional seawater desalination plants, sourcing from ground or
surface water should be limited to areas with high water availability. Local water prices should be
monitored, and countermeasures should be taken if prices increase due to hydrogen production.
Desalination plants should fulfil ecological standards and should be powered by renewable
energy. Investment in improved local water infrastructure to reduce losses and evaporation, and
additional water production through seawater desalination could support local sustainable
• Land-use change for hydrogen production and especially renewable electricity production should
not take place in ecological protected areas. Local stakeholder consultation should make sure that
local and sometimes informal land rights are not violated. Economic participation of the local
population and enabling co-benefits (such as shading local agricultural areas by agri-PV systems)
could be options to further support local sustainable development.
• Socio-economic risks need to be mitigated by following the due diligence procedures(definition of
sector-specifc risks and adequate measures to mitigate those risks) and human rights violations
should be prevented. In addition, corruption should be prevented through initiatives that define
standards for economic participation and make the flow of money transparent. Socio-economic
participation could be supported by guaranteeing a certain share of local workforce, establishing
a local supply chain for technology, direct investments in R&D and local capacity building
• CO2 use should be limited to those sources that create a short-term carbon-cycle with the
atmosphere. Therefore, we suggest to only use CO2 from Direct Air Capture (DAC) or from waste
streams from industrial processes based on sustainable biomass.
• Raw materials and transport were not in the focus of our research. However, we suggest
specifying that compliance with due diligence and international labour safety standards is
mandated for the whole value chain. Concerning transportation, the higher the losses the more
hydrogen needs to be produced in the firs t place with all the sustainability dimensions to be
considered described in the sections above. Therefore, the most efficient transport mode should
be considered to keep overall sustainability impacts in the exporting country low.
respective criteria and standards . If an international agreement on sustainability criteria leads to
weak criteria, more ambitious specifications for the European hydrogen market should be provided.
Standards relate to sustainability dimensions but also to the way certain assessments are carried
out at the project level (such as the Environmental Impact Assessment). Also, an international
standard securing a low ecological impact of seawater desalination is missing and should be
compliance with sustainability standards. On the one hand, local institutions are needed for the
implementation of certification systems and for robust monitoring and auditing. On the other hand, a
private/public initiative could foster socio-economic standards and monitor them.
Close cooperation with exporting countries will ensure that the way sustainability dimensions are
defined and addressed can be aligned between exporting and importing countries. This way a clear
pathway towards the uptake of sustainable green hydrogen can be supported.
Read the complete working paper here
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